UPM Annual Report 2025

We are UPM

Governance

Accounts and performance

Sustainability

UPM in brief

Our strategy

Our businesses

Our commitments Alignment with international principles Our approach is based on the UN Guiding Principles on Business and Human Rights (UN GPs) and guided by our Code of Conduct and related policies, rules, and guidelines. We expect a similar commitment from our suppliers, third parties, and joint venture partners, as set out in our Supplier and Third-Party Code. Safe work environment We ensure the health, safety, and security of our employees, those working on our sites and premises, visitors, and others impacted by our operations. Focus on salient issues We use our corporate salient human rights assessment, along with input from relevant stakeholders, to identify our material human rights issues. UPM’s corporate salient human rights issues are health and safety, land rights and community engagement, terms and condi tions of work, forced labor, and children’s rights. We continue to prioritize our efforts accordingly, recognizing that our impact on people evolves as our business changes, and our due diligence approach develops. Human rights risks are regularly assessed at the business area, function, and corporate levels. This process includes identifying actual and potential risks and impacts, evaluating their severity and likelihood, and prioritizing the most significant issues for action. Promoting social responsibility in our supply chain Contractors carry out a significant proportion of our operations, particularly in maintenance at our production units, construction, and forestry. We ensure responsible subcontracting through clear requirements. Our approach includes setting limitations on subcontracting, requiring commitment to social responsibility and labor rights, engaging with contractor workers, and applying approval and due diligence processes. Human rights due diligence is a continuous process Decent work We promote decent work in our value chains and Our priorities

Creating value for people and society

play our part in building a more equitable society. We actively promote fair pay. Our commitment to gender pay equity and living wages aligns with the UN Sustainable Development Goals. Identifying and prioritizing salient human rights issues We prioritize the most serious human rights risks and impacts and take action to address them.

Collaborating on human rights Respect for human rights forms the basis of our social responsibility agenda and 2030 targets.

Zero tolerance for human rights violations

CASE STUDY In focus

We prohibit all forms of forced labor, modern slavery, and child labor. Discrimination is not tol erated. We do not accept any form of inhumane treatment within our operations or across our value chain.

Strengthening contractor collaboration

Each year, more than 50,000 con tractor employees work on produc tion sites and in forestry operations. Many of these roles are performed by subcontracted workers, who are often from other countries. Long subcontracting chains can make en suring fair conditions and preventing exploitation challenging. In 2025, we piloted an enhanced contractor management model at two Finnish pulp mills during shutdowns. The model limits subcontracting chains to one main contractor and a maximum of two subcontractors. It also adds more detailed social responsibil ity requirements and improves UPM’s subcontractor approval and background checks. Additionally, it includes face-to-face interviews with subcontractors’ employees. We conducted over 100 contractor interviews during the shutdowns. The interviews revealed concerns related to overtime, compensation and safety equipment. Corrective actions have been initiated, and develop ment work continues. This work sup ports our zero-tolerance approach to exploitation and strengthens our commitment to safe and fair working environments.

We also equip our personnel to identify and ad dress social responsibility risks in subcontracting chains through internal training. Training and awareness All UPM employees are required to complete mandatory Code of Conduct training, which covers essential topics such as human rights and ethical business practices. We provide spe cialized training on supplier requirements such as the UPM Supplier and Third-Party Code, and anti-corruption to ensure responsible sourcing. Contractors working on UPM sites receive com prehensive safety induction and training tailored to the specific risks of their work environment. Collaboration and stakeholder engagement Promoting human rights requires both internal capacity building and active collaboration across our value chain. We maintain continu ous dialogue with our stakeholders, including suppliers, contractors, and forest owners, to ensure shared understanding and progress. Internally, we organize human rights workshops to build awareness and support effective local implementation. Externally, we participate in collaborative forums such as Together for Sus tainability (TfS) and the UN Global Compact (UNGC) Labour and Decent Work Program. Through these forums, we share insights and best practices, and contribute to development and capacity building across industries.

In a time of ongoing instability, with socio economic pressures and an urgent need to address the climate change and biodiver sity loss, collaboration is essential to drive progress. We are committed to respecting human rights throughout our operations, including our employees, suppliers, contrac tors, and surrounding communities.

Actions in 2025 • About 600 UPM employees took the training in the renewed UPM Supplier and Third-Party Code. • A new UPM standard for local community engagement and the Share and Care Pro gram, which provides guidelines for local dialogue, issue management, and community development contributions. • Limitations on the use of subcontractors introduced. • Over 100 subcontractor worker interviews held in connection to maintenance shutdowns in Finland. • Organized internal training to help personnel identify and address social responsibility risks in subcontracting chains.

Sustainability Statement, ESRS S1 Own workforce on page 208 Sustainability Statement, ESRS S2 Workers in the value chain on page 222 Sustainability Statement, ESRS S3 Affected communities on page 229

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UPM Annual Report 2025

UPM Annual Report 2025