UPM Forestal Oriental - Social and Enviromental Report 2014

Code of Conduct

UPM’s objective is to carry out pro- fitable, long-term activity in a respon- sible and ethical manner, taking econo- mic, human, social and environmental aspects into account. Efforts to achieve sustainable deve- lopment and continuous improvement are part of UPM’s usual way of wor- king. Transparency, confidence and initiative are the UPM’s basic values. This Code of Conduct defines the way of working of all UPM employees, including managers and executives, without exception. Where necessary, it is complemented with rules and more detailed guidelines, approved by the executive team, divisions and de- partments. All the company’s rules and guidelines must comply with the entire UPM Code of Conduct. In terms of compliance with stan- dards and delivery of information, UPM is legally required to comply in all its operations with the applicable laws and regulations in the places whe- re it carries out its activity. This invol- ves, among other things, laws and re- gulations relating to securities markets, corporate governance, safety and res- ponsibility for products, occupational health and safety, staff, the environ- ment, intellectual property protection, protection of individual privacy and equality in the workplace. As a publicly traded company, UPM is committed to complying with all obligations stipulated by the listing rules of the HEX and NYSE markets, in addition to other applicable rules. It is also a UPM standard that all reports and documents delivered to public bodies and the relevant regulatory authorities, as well as communications sent to its investors and other people

with an interest in the company, con- tain accurate and comprehensive infor- mation based on verified data in order to provide a materially correct over- view of the company’s operations. This information will be disclosed to the public in general on a fair and timely basis. Regardless of the position filled, no one at UPM has the right to expect or allow illegal activities. Conflicts of interest, gifts and bribes UPM employees are expected to work to promote the interests of UPM and to act responsibly in doing so. UPM prohibits any corruption or bribery in its operations. Neither UPM nor its employees will pay or offer the payment of bribes or other illegal payments. Employees are prohibited from obtaining personal benefits from the opportunities that may arise through the use of their posi- tion at the company or of information pertaining to this. UPM employees must avoid any activity that gives rise to conflicts of interest. This includes the offer or acceptance of gifts or per- sonal benefits that go beyond reasona- ble hospitality offered during normal activities. There would be a conflict of inter- ests if an employee or a family member received undue personal benefits as a result of the employee’s role at UPM. In addition to cash deliveries, arti- cles of symbolic value are also exclu- ded (maximum value of 100 Euros). Furthermore,UPM employees must not compete with UPM. The company does not support any candidate, politi- cal party or political group. It is expec- ted that all employees shall make pro- per use of UPM assets, use them effi-

ciently and not use them for unauthori- sed purposes. The delivery of confiden- tial customer information or of other types of confidential information to any outside individual or entity, or the use of such information against the interests of UPM is prohibited without exception. Respect for and promotion of hu- man rights UPM respects human rights in its operations, as defined in the Universal Declaration of Human Rights of the United Nations, and promotes its im- plementation within its sphere of in- fluence. Among the rights that the company considers fundamental and universal are: freedom of thought, opi- nion, expression, worship and meeting, as well as protection against any discri- mination on grounds of race, age, na- tionality, gender or sexual orientation

The company does not tolerate the

use of slave or child labour.

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