UPM CODE OF CONDUCT EVERY CHOICE MATTERS · EVERY CHOICE MATTERS. THIS CODE OF CONDUCT BELONGS TO OUR COMMITMENT 1. Our commitment to integrity 4 OUR PEOPLE AND OPERATIONS 2. Respect

UPM CODE OF CONDUCT

EVERY CHOICE MATTERS

THIS CODE OF CONDUCT BELONGS TO

OUR COMMITMENT1. Our commitment to integrity 4

OUR PEOPLE AND OPERATIONS 2. Respect people and human rights 63. Taking care of the environmental impact and product safety 8

BUSINESS INTEGRITY 4. Zero-tolerance for corruption and bribery 105. Avoid conflicts of interest 126. Compliance with competition laws 147. Protect assets and information 16

OUR STAKEHOLDERS 8. Know with whom you trade 189. Engaging with our stakeholders and society 20

VOICE YOUR CONCERNS10. Compliance involves everyone 22

Table of Contents

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UPM CODE OF CONDUCT2

Dear colleagues,

We need to do the right thing, no matter where we are, who we are dealing with, or what the situation is. We do not compromise our standards of integrity under any circumstances. Our Code of Conduct and our values support an engaging work environment and help us to navigate the changing business landscape. This builds the foundation for our long-term success.

It is an important part of our culture of integrity that employees feel comfortable to voice any concerns they have, and can trust UPM to take the appropriate actions. If we are worried about anything, we must speak up and take action.

We are all responsible for building this culture of integrity, with everything we do and every choice we make. This is why every one of us needs to understand our Code of Conduct and use it as a compass to guide our work. The choices we make matter!

Yours sincerely,

Jussi Pesonen President & CEO

UPM CODE OF CONDUCT 3

UPM VALUES Trust and be trusted

Achieve together Renew

with courage


We believe integrity is fundamental to all our business operations and provides the foundation for our continued success and growth.

We comply with applicable laws and regu-lations in all our operations. For us, however, integrity starts with our values and everyday ways of working.

Our Code of Conduct sets out the principles that help us make ethically sound decisions. We are all responsible for knowing our Code of Conduct, knowing how to do the right thing and understanding why it is important.

By making the right choices, we protect the value created at UPM every day. Acting with integrity builds our reputation as a trustworthy partner, supplier, customer and employer.

At UPM, we recognise and actively promote the United Nations Sustainable Development Goals, which guide our work in sustainable development and the continuous improvement of our operations. As a member of the United Nations Global Compact, we value its ten principles relating to human rights, labour, environment and anti-corruption.

Our commitment to integrity1.

BUSINESS INTEGRITYOUR PEOPLE AND OPERATIONS

OUR COMMITMENT VOICE YOUR CONCERNS

OUR STAKEHOLDERS

Integrity means doing what is right

As UPM employees, we are expected to:• Read, understand and comply with our Code of Conduct• Speak up and voice our concerns if we suspect any misconduct• Ask for advice from our managers or UPM Compliance when uncertain

about the right thing to do

In addition, UPM managers are expected to:• Lead by example• Communicate our corporate policies and procedures to their teams

and take the time to discuss how they apply to the team• Promote an atmosphere in which team members feel they can voice

their concerns• Listen to the concerns of team members and escalate any suspected

misconduct that they become aware of• Supervise and support their teams in meeting the expectations above

When you are not sure how to move forward

Think about your planned actions and ask yourself:• Are they in line with our

Code of Conduct?• Are they legal?• Are they ethical?• Would I want to read about them

on social media or in newspapers?

If the answer is no to any of these questions, stop and ask for help to find the right path.

LEARN MOREThe UN Guiding Principles on Business and Human RightsThe Ten Principles of the United Nations Global CompactThe United Nations Sustainable Development GoalsOECD Guidelines for Multinational Enterprises

CODE OF CONDUCT HELPLINE

If you have any questions about the Code of Conduct, you can always contact: [email protected]

Find more information on our values, integrity and policies on the UPM intranet (for UPMers) on codeofconduct.upm.com or the UPM corporate website on upm.com/codeofconduct


VOICE YOUR CONCERNS


OUR STAKEHOLDERSOUR COMMITMENT

mailto:[email protected]

https://www.upm.com/investors/governance/governance-guidelines/code-of-conduct/

UPM is committed to respecting human rights in line with the United Nations Guiding Principles on Business and Human Rights. We promote decent working conditions. We do not tolerate the use of forced or child labour under any conditions. We aim to empower and engage employees at all levels of the organisation through responsible leadership.

All our employees must respect everyone’s right to freedom of thought, opinion, expression, religion and right to assemble peacefully, as well as freedom from discrimination based on race, age, nationality, gender or sexual orientation. We do not tolerate sexual harassment

or any other form of harassment.

We can all play our part in making our workplace inspiring, diverse and inclusive. Employees are encouraged to be active in their personal and professional

development and growth.

Well-being, health and safety

Employee well-being and health are important to UPM. We never compromise on safety, and we only work with business partners that share our commitment to health and safety. We are all responsible

for working safely at all times, and we must comply with relevant occupational health and safety laws, as well as with our corporate

safety rules and standards. All managers must instruct, supervise and support their teams, so they can work safely.

Respect people and human rights2.


VOICE YOUR CONCERNS

BUSINESS INTEGRITY OUR STAKEHOLDERSOUR COMMITMENT OUR PEOPLE AND OPERATIONS


• Strive to promote diversity, include people with different competences, experiences and backgrounds in our teams, and do not treat anyone differently because of their race, age, nationality, gender or sexual orientation.

• Build and encourage a culture in which people can have diverse views and opportunities to contribute.

• Consider how you can improve your workplace’s atmosphere and inspire others.• Speak up if you perceive harassment or other inappropriate behaviour, whether

it is targeted to you or someone else.• Take responsibility for your personal and professional development.• Make sure that your work performance is not impaired by, for example, alcohol

or drugs.• Expect and encourage others to comply with UPM’s safety requirements.

If you notice unsafe work practices, you must speak up. Report any accidents and unsafe conditions immediately. Never assume that someone else reported a risk or concern.

• Be a role model for health and safety and lead by example. Always look out for yourself and your colleagues and take care of your personal well-being.

WHAT IS THE RIGHT THING TO DO?

Contribute andengage others

LEARN MOREUN Universal Declaration of Human RightsILO Declaration on Fundamental Principles and Rights at Work

VOICE YOUR CONCERNS



We comply with relevant environmental laws and pay close attention to how our operations impact the air, climate, water, land and biodiversity. We aim to minimise our adverse effects, including how we use land. We continuously measure and assess the direct and indirect environmental loads and impacts of our operations and promote the use of advanced technologies.

We want all our employees to be aware of environmental issues in their day-to-day work. This is why we are all expected to act responsibly and share best practices. Any action that can affect people and the environment negatively must be considered carefully.

Our employees must manage UPM’s environmental loads systematically, keeping in mind our principle of continuous improvement. Chemicals must be handled safely in accordance with internationally recognised management systems.

We strive for product stewardship that takes into account the product’s lifecycle as a whole. We are all responsible for making sure UPM’s products are safe for the use they are meant for and meet their regulatory requirements.

Taking care of the environmental impact and product safety

3.

Reduce, reuse,

recycle!

VOICE YOUR CONCERNS


• Be aware of the environmental impacts and legal requirements of your work and workplace.

• Avoid unnecessary risks and act before there is a problem.

• Share your best practices with others.• Perform all measurements, analyses and reporting

truthfully and accurately.• Do not waste resources (water, energy, raw materials)

and use them efficiently.• Handle chemicals and all waste with care

and according to instructions.• Report any activities that might pose a risk

to the environment.• Make sure that products meet their requirements

(for example, REACH and Ecolabel criteria).



VOICE YOUR CONCERNS

BUSINESS INTEGRITYOUR COMMITMENT OUR STAKEHOLDERSOUR PEOPLE AND OPERATIONS

Zero-tolerance for corruption and bribery

4.

UPM’s guiding principle is clear: We do not tolerate corruption or bribery in any form. We never offer or pay bribes or allow bribes to be paid to government officials or private persons, and we never solicit or accept bribes.

Specifically, we must not give or offer anything of value to improperly influence a business decision to get business, keep business or gain an unfair advantage. We cannot do so directly or indirectly, meaning through a third party acting on UPM’s behalf. Likewise, we must not, directly or indirectly, ask for or accept anything of value that might affect or appear to affect our ability to be objective in our business decisions. “Anything of value” must be broadly understood and includes any payment, loan, discount, political or charitable contribution, reimbursement, gift, gift card, meal, entertainment, trip, employment or internship, business opportunity, service or other benefit.

Gifts or hospitality, given or accepted, must have a legitimate business purpose and must always be reasonable in kind and size. We must obtain prior approvals for any gifts, hospitality and travel expenses in accordance with our corporate policies.

All requests and offers of any improper payment, benefit, gift or hospitality must be rejected and reported without delay to UPM Legal.

No compromises, no excuses,

no exceptions!


OUR PEOPLE AND OPERATIONS

OUR COMMITMENT BUSINESS INTEGRITY OUR STAKEHOLDERS VOICE YOUR CONCERNS

Government interactions• Do not give, offer or accept

anything of value when dealing with a government official without first consulting UPM Legal.

• Understand that the term “government official” has a wide range of meanings under various anti-corruption laws. It often includes any officer, employee or representative of or candidate for any government department, agency, state-owned or state-controlled enterprise, municipality, parish, political party or public international organisation.

• Do not make facilitation payments, i.e. payments to government officials to speed up routine government actions, such as processing paperwork or obtaining a permit.

Business partners• Remember that it is a violation

of various laws and company policy to give, offer or accept bribes, kickbacks or other payments to or from private business partners or other parties that are used to influence business decisions or secure special treatment.


Third parties• Remember that you and UPM may

be legally responsible for the improper conduct of a third party, such as an agent, consultant, adviser, joint venture partner, local partner, distributor, or supplier acting on behalf of UPM.

• Perform the appropriate risk assessment and due diligence in accordance with corporate policies and procedures. When entering into or renewing a contract with any third party, make sure to include the contractual terms specified in corporate policies and procedures.

• Only pay reasonable and justifiable commissions and fees to third parties, based on the services delivered and the contract between UPM and the third party.

Gifts, hospitality, travel and entertainment expenses• Do not offer, give or accept any

gift or hospitality, meal, travel or entertainment that is excessive or used to influence improperly business decisions or secure special treatment or that could create the appearance of impropriety.

• Do not give or accept gifts of cash or cash equivalents, i.e. items that are easily converted into cash. Cash equivalents include, but are not limited to, cash cards, prepaid gift cards and gift certificates.

• Report expenses relating to all gifts and hospitality, meals, travel or entertainment, including the names and titles of attendees, dates and sums spent, in accordance with our corporate policies and procedures. UPM reimburses the reasonable work-related expenses of our employees. Payments covering the expenses of our business partners are made in accordance with internal procedures.


VOICE YOUR CONCERNS


OUR COMMITMENT OUR STAKEHOLDERSBUSINESS INTEGRITY

5.

We are all expected to act in the best interest of UPM. This means we must all avoid conflicts of interest, among other things. A conflict of interest arises when your personal interests conflict with UPM’s interests. Even the appearance of a conflict of interest can damage the company and our reputation.

Personal interests

Personal interests, for example, holding shares of or having a connection with our suppliers, customers or competitors, can create conflicts of interest. When you have a personal interest, you must not be involved in any decision-making relating to the business partner in question. Minor shareholdings of publicly traded companies do not create a conflict of interest.

You must not work for a company competing with UPM or be engaged in other professional activities with it. You must not engage in any professional activities that could have a negative impact on your job performance by demanding too much of your time or conflicting with your work at UPM. Being a board member, director, officer or advisory member or having a similar position at another organisation can also interfere with your obligations to UPM and create a conflict of interest.

Avoid conflicts of interest

Personal relationships

We all may have relatives or friends who work for or have financial interests in customers, suppliers or competitors of UPM or any of its subsidiaries. This kind of a connection creates a potential conflict of interest: Others might think that you give special treatment to such a business partner or that they may influence the actions you take on behalf of UPM. A conflict of interest arises if you have decision-making power or influence in dealing with that business partner.

Note that a conflict of interest also exists if you supervise or are supervised by a family member or equivalent person or if you are considering hiring such a person. Direct supervision or hire by such a person is not allowed.

Disclose and discuss

We must inform our managers of any real or potential conflicts of interests and obtain permissions, if necessary. Each situation is assessed case by case, and actions are taken to ensure that our culture of integrity is not compromised.


VOICE YOUR CONCERNS



• Do not derive unjust personal benefit from opportunities created through your position in the company or through the use of information or assets you have access to in your work.

• Recuse yourself from all decision-making that creates a real or potential conflict of interest or could be perceived as creating one.

• Make sure that all your decisions on the job are objective and made with UPM’s business interests in mind.

• Tell your manager if you are considering taking any outside job or position to discuss possible conflict of interests. Get written permission, if necessary.

• Document and make known all potential and real conflicts of interests to your manager, regardless of whether you think they influence your decisions.


Every choice makes

a difference!

Could my personal interests or relationships influence the

decision I am about to make or interfere with UPM’s interests?

If yes, discuss it with your manager

If you are not sure, discuss it with your manager

If not, could someone else nonetheless perceive it that way?

If yes, discuss it with your manager

If not, it is probably not a conflict of interest

Is there a conflict of interest? Ask yourself:


VOICE YOUR CONCERNS



Competition laws protect and promote effective and fair competition. They require that every company acts independently on the market, without engaging in practices that could hinder competition between companies.

Competition laws forbid agreements and other practices that have the objective or effect of restricting or distorting competition. They also regulate the behaviour of companies that have dominant market positions. So, our actions must always comply with all applicable laws governing competition.

Compliance with competition laws6.

Dealing with competitors• Avoid all unnecessary contacts with

competitors. All competitor contacts must have a clear and lawful purpose.

• Request prior permission for your contacts with competitors based on our corporate policies and procedures.

• Do not discuss or provide any sensitive information to a competitor. Examples of sensitive information include pricing, costs, production volumes, discounts, operating rates, market allocations and mill closures. This applies to discussions with all of UPM’s competitors on all occasions, including informal (social) events and unplanned meetings.

• Refuse to answer or comment if a competitor opens a discussion about any of the sensitive subjects mentioned above and inform UPM Legal.


In practice, this means:• Do not engage in price fixing, customer allocation,

division of product or geographic market, bid rigging, boycotting or limitation, reduction or stabilization of production, or agreements on resourcing with competitors.

• Do not discuss or exchange sensitive information with competitors in violation of applicable competition laws.

• Follow UPM’s corporate policies and procedures when in contact with competitors.

• Follow UPM’s corporate policies and procedures when attending any trade and other professional associations.

• Make sure any commercial agreements with competitors, customers, distributors, suppliers or other business partners comply with competition laws.

• Make sure we do not abuse a dominant market position, if we have one.


VOICE YOUR CONCERNS



Information exchange• Do not share commercial information for

statistical purposes with competitors without first consulting UPM Legal. You must not do so directly or indirectly, meaning through a third party, for example, a trade association.

• Always keep confidentiality in mind and do not share with your business partners any other information than what is necessary for the planned transaction. This is important to remember, for example, if you deal with customers or suppliers that are competitors in another UPM business area. You are not allowed to disclose any sensitive information pertaining to the other UPM business area to its competing customer or supplier, and you cannot share sensitive information concerning the customer or supplier with the competing UPM business area.

Price announcements• Do not publicise information on price

increases before consulting UPM Legal.

Trade association participation• Do not participate in any trade associations

that are not recorded in our database in accordance with applicable corporate policies and procedures.

• Do not participate in meetings without an agenda.

• Review meeting agendas in advance to make sure that the topics are legitimate. If in doubt, consult UPM Legal.

• Do not share sensitive information at trade association meetings.

• Protest immediately if any other participant discloses such information or otherwise acts in contravention of competition laws. If this has no effect, leave the meeting at once and inform UPM Legal without delay. When possible, have your protest and/or exit documented in the meeting minutes.

• Check whether the minutes properly reflect the discussions of the meeting. Request modifications and amendments, if necessary.

• Remember that competition law also applies to all side and informal meetings.

Relations with distributors, customers and suppliers• Do not restrict our customers’

freedom to set their resale prices.• Consult UPM Legal before entering

into any restrictive agreements (such as exclusivity or non-compete) with suppliers or customers.

Abuse of dominant market position• Contact UPM Legal if you think that

we may have a dominant market position for a specific product in a specific geographical area.

Investigations• Contact UPM Legal immediately

and follow their instructions in case of an unannounced investigation – dawn raid – by any competition authority.


Business success builds on

compliance


VOICE YOUR CONCERNS



Tangible and intangible assets

In our everyday work, we are responsible for UPM’s and our business partners’ assets, such as machinery, equipment, raw materials, vehicles, IT and mobile devices, funds, intellectual property and information. We are expected to handle them with care and protect them from damage, loss, theft and misuse.

All our employees must take appropriate measures to safeguard our and our business partners’ confidential information. We handle confidential information with care and share confidential information only with those who have the right to access the information and need it to do their work. We protect UPM’s intellectual property – inventions, patents, copyrights, trademarks and trade secrets – appropriately.

We follow our corporate policies and procedures to protect data from threats and unauthorised and illegal use. UPM has the right to access and use the data created or shared by our employees in the company systems and monitor and investigate information and system usage to the extent permitted by law. We respect the privacy of our colleagues, stakeholders and their representatives by handling personal data in compliance with relevant laws and company policies and procedures. We use and utilise technology ethically and responsibly.

Protect assets and information7.

Prevent, protect,

pay attention!

Disclosure and inside information

As a publicly listed company, we must comply with applicable laws and rules of the stock exchange when making UPM’s information public. Only designated company employees can make public statements to the media on behalf of UPM. We are committed to

following the rules and regulations relating to market abuse and inside information, such as restrictions on trading and disclosure.

Decision-making and document trail

Our decisions must be made with UPM’s best interests in mind and be based on appropriate risk assessments. Legal and financial approval procedures are in use throughout our organisation, and we are committed to following them. These procedures include risk mitigation practices, such

as determining authorised persons, monetary limits and segregation of duties.

All business transactions must be recorded in our books and accounts accurately and fairly. Accurate recordkeeping and reporting help us meet our legal and regulatory requirements, for example, concerning taxation. Our employees must know and follow the corporate policies that relate to maintenance, storage and disposal of records.


VOICE YOUR CONCERNS



Assets• Do not misuse company assets or information,

for example, for personal or non-UPM business or for illegal or unethical activities.

• Do not use the services or time of your colleagues for personal gain.

Information• Use appropriate IT tools and follow corporate

policies on information security to safeguard the confidentiality of data and to protect data against cyber risks. When dealing with personal data, always remember to plan first, limit use, make it safe and delete when obsolete.

• Do not discuss confidential matters in public areas or on social media or with relatives or friends.

• Do not share confidential information from your former employers or ask others to do so. If you leave UPM, do not share our confidential information with others.

• Direct all media contacts to UPM Stakeholder Relations for all comments on company matters.

• Use caution if third parties request information about the company from you, for example, as part of their “Know Your Customer” procedures.


Make sure that the requestor has a legitimate purpose for the request, do not provide any confidential information without appropriate confidentiality agreements or obligations in place and safeguard personal data.

• Safeguard UPM’s intellectual property by maintaining adequate legal protection and confidentiality and respect the intellectual property of third parties.

• Remain up to date on corporate policies and procedures relating to insider issues. Contact UPM Legal if you have questions.

Books and records• Follow UPM’s approval procedures

and the subsidiary governance framework when making decisions in UPM group companies.

• Do not falsify the books, records or accounts of the company.

• Do not record expenses without the supporting documentation or justification required by corporate policies and procedures.

• Report suspicious transactions, payments or expenses to a representative of UPM Internal Audit or UPM Legal.


VOICE YOUR CONCERNS



Do you know your

business partner?

By knowing our customers, suppliers and other business partners and developing business relationships with them, we can improve our business performance, supply security and business continuity. At the same time, we can mitigate the risk of becoming involved in illegal business activities and suffering losses or reputational damage due to such relationships. This is why we must select our business partners carefully using objective criteria, such as requiring them to conduct business in compliance with applicable laws. In addition, we expect our suppliers and business partners that act on our behalf, including agents and intermediaries, to comply with the UPM Supplier and Third Party Code.

We want to identify and address the risks relating to our business partners before entering any business relationship with them. We also monitor our business partners throughout our business relationship. We focus particularly on managing risks related to trade compliance, bribery and corruption (see section 4), human rights (see section 1), money laundering, fraud and various financial matters. Moreover, social, environmental and availability risks are carefully managed in our supply chain.

Know with whom you trade8.

Follow trade compliance regulations and anti-money laundering laws

Like any other global company, we must comply with all applicable national and international trade compliance regulations.

Trade compliance includes regulations governing import, export and domestic trading of goods, as well as international sanctions and restrictive trade practices.

Money laundering is a process by which funds generated through criminal activity – such as fraud, tax evasion, human trafficking and bribery – are moved through legitimate businesses to hide their criminal origin. We do not conduct business in violation of applicable anti-money laundering, anti-terrorism and financial crime laws.

Source responsibly

We are committed to responsible sourcing practices. We set require-ments for our suppliers and expect them to take these requirements further in their supply chains. In addition to the conditions set out in the UPM Supplier and Third Party Code, these requirements concern, for example, the origin of raw materials, decent working conditions and prohibition of child and forced labour.


VOICE YOUR CONCERNS



Know your business partners• Know your customers, suppliers and other business partners.

Obtain and maintain relevant and up-to-date information about them by conducting risk-based due diligence and credit and other financial checks in accordance with our corporate policies and procedures.

• Do not make commitments if you have concerns about a business partner’s ethical behaviour.

• Aim at developing the business relationships continuously, monitor the activities of business partners and act if you detect a risk that could have an impact on UPM.

Suppliers• Communicate UPM’s requirements clearly, including

the UPM Supplier and Third Party Code.• Select suppliers based only on predefined criteria and

comprehensive risk assessment.• Safeguard confidential information and share information about

product performance or prices on a need-to-know basis only.


Transactions• Keep complete and accurate records of all business transactions.• Do not accept payment in cash or cash equivalents without

following the applicable internal procedures.• Make payments to business partners, such as suppliers and agents,

with care. Make sure that payments go to the person or company that provides the goods or services and not to any unrelated party. Also, make sure that payments go to the country where the partner either does business or has sold goods or provided services to UPM. Contact UPM Legal if you uncover irregularities.

• Do not ignore red flags, such as complex or unusual payment structures, multiple payments from or to various parties, requests for payments to unrelated accounts or, for customers, large increases in order volumes that are inconsistent with normal ordering patterns and lack clear business purposes.

• Consult with UPM Legal if you have any questions about a transaction.


VOICE YOUR CONCERNS



Our goal is to be a trusted partner. We aim to understand stakeholder-specific expectations and engage in dialogue with various stakeholders to discuss UPM’s targets, operating principles and the challenges we face. We respect the right to different opinions, as we want to foster dialogue with our stakeholders and society.

We recognise our significant societal impact on our surrounding communities. Our aim is to contribute positively to their economic, environmental and social development and to minimise any negative impacts of our operations.

We participate in the development of our local communities through various projects and initiatives and disclose our activities openly. When UPM partners with local governments to conduct such projects and initiatives, we ensure the integrity of our actions and comply fully with applicable anti-corruption laws and company policies.

Engaging with our stakeholders and society

9.


VOICE YOUR CONCERNS


OUR COMMITMENT OUR STAKEHOLDERS


Stakeholder dialogue

starts with trust

• Consult with UPM Legal before partnering with any local government in an investment or a corresponding development project in a local community.

• Do not make political contributions or otherwise support political candidates, parties or groups on behalf of UPM. Keep your political activities clearly separated from your work.

• Make sure donations and sponsorships are approved in accordance with our corporate policies and procedures on sponsorships, donations and employee volunteering.

• Be open to constructive dialogue with all stakeholders in accordance with UPM policies on disclosure.

• Listen to and welcome diverse opinions and express your opinions constructively.


VOICE YOUR CONCERNS


OUR COMMITMENT OUR STAKEHOLDERS

We are all responsible for maintaining the integrity and ethical standards of UPM. If we suspect misconduct, we are all obligated to speak up and report it, as well as listen to the concerns raised by others. We must never assume that someone else has reported a risk or concern.

This Code of Conduct is the basis for our various compliance programmes, policies and procedures, which address the topics discussed in more detail. We also maintain a system specifying how to detect compliance risks, how to respond to them and how to control and monitor them. We continuously communicate the importance of compliance to our employees and others representing UPM.

Voice your concerns

All employees must promptly report any suspected or observed breach of the law, this Code of Conduct or other UPM corporate policies to • their managers or • a representative of UPM Legal, UPM HR or UPM Internal Audit or• use UPM’s Report Misconduct channel.

This makes it possible for us to deal with issues and correct them in a timely manner and prevent them from happening again at the same place or elsewhere in the organisation.

We review misconduct reports carefully, handle personal data appropriately and maintain the confidentiality of reports to the extent possible.

We do not tolerate retaliation against any person who, in good faith, reports suspected misconduct or participates in an investigation to resolve suspected misconduct. Examples of retaliation include demotion, dismissal, denial of promotion, salary reduction and any kind of threatening, bullying or harassment.

Compliance involves everyone10.



OUR COMMITMENT OUR STAKEHOLDERS VOICE YOUR CONCERNS

Employees who violate the law, the UPM Code of Conduct or other UPM policies are subject to disciplinary action up to and including termination of employment. Other disciplinary actions include reprimand, warning and loss of incentives.

Examples of misconduct that may result in disciplinary action:• Violating UPM policies• Requesting others to violate

UPM policies• Failure to promptly raise a known

or suspected violation of UPM policy• Knowingly providing a false report

or providing false information in an investigation

• Failure to cooperate in UPM investigations of possible policy violations

• Retaliation or tolerating retaliation against an employee for reporting suspected misconduct

Other possible consequences of misconduct include civil sanctions (for example, damages and breach of contract) and criminal sanctions (for example, fines and imprisonment).

Web: upm.com/reportmisconductEmail: [email protected]

Postal mail: UPM-Kymmene CorporationHead of Internal Audit/Compliance

PO Box 380FI-00101 Helsinki, Finland

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Silence is not an option.Do the right thing!



OUR COMMITMENT OUR STAKEHOLDERS VOICE YOUR CONCERNS

https://www.upm.com/reportmisconduct

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UPM CODE OF CONDUCT EVERY CHOICE MATTERS · EVERY CHOICE MATTERS. THIS CODE OF CONDUCT BELONGS TO OUR COMMITMENT 1. Our commitment to integrity 4 OUR PEOPLE AND OPERATIONS 2. Respect

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