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UPM CODE of CONDUCT EVERY CHOICE MATTERS OUR COMMITMENT Table of Contents 1

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UPM CODE of CONDUCT EVERY CHOICE MATTERS OUR COMMITMENT Table of Contents 1 UPM CODE OF CONDUCT EVERY CHOICE MATTERS OUR COMMITMENT Table of Contents 1. Our commitment to integrity 4 OUR PEOPLE AND OPERATIONS 2. Respect people and human rights 6 3. Taking care of the environmental impact and product safety 8 BUSINESS INTEGRITY 4. Zero-tolerance for corruption and bribery 10 5. Avoid conflicts of interest 12 6. Compliance with competition laws 14 7. Protect assets and information 16 THE UMBRELLA SYMBOL OUR STAKEHOLDERS indicates that there are more 8. Know with whom you trade 18 detailed rules available in our intranet. 9. Engaging with our stakeholders and society 20 VOICE YOUR CONCERNS 10. Compliance involves everyone 22 THIS CODE OF CONDUCT BELONGS TO 2 UPM CODE OF CONDUCT 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 OUR COMMITMENT OUR PEOPLE AND BUSINESS INTEGRITY OUR STAKEHOLDERS VOICE YOUR OPERATIONS CONCERNS 1. Our commitment to integrity 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 UPM VALUES Trust and of our operations. As a member of the United be trusted Nations Global Compact, we value its ten principles relating to human rights, labour, environment and anti-corruption. Achieve together Renew with courage 4 UPM CODE OF CONDUCT OUR COMMITMENT OUR PEOPLE AND BUSINESS INTEGRITY OUR STAKEHOLDERS VOICE YOUR OPERATIONS CONCERNS As UPM employees, we are expected to: When you are not sure • Read, understand and comply with our Code of Conduct how to move forward • Speak up and voice our concerns if we suspect any misconduct • Ask for advice from our managers or UPM Compliance when uncertain Think about your planned actions about the right thing to do and ask yourself: • Are they in line with our In addition, UPM managers are expected to: Code of Conduct? • Lead by example • Are they legal? • Communicate our corporate policies and procedures to their teams • Are they ethical? and take the time to discuss how they apply to the team • Would I want to read about them • Promote an atmosphere in which team members feel they can voice on social media or in newspapers? their concerns • Listen to the concerns of team members and escalate any suspected misconduct that they become aware of If the answer is no to any of these • Supervise and support their teams in meeting the expectations above questions, stop and ask for help to find the right path. Integrity CODE OF CONDUCT HELPLINE means doing If you have any questions about the Code what is right of Conduct, you can always contact: [email protected] LEARN MORE Find more information on our The UN Guiding Principles on Business and Human Rights values, integrity and policies The Ten Principles of the United Nations Global Compact on the UPM intranet (for UPMers) The United Nations Sustainable Development Goals on codeofconduct.upm.com OECD Guidelines for Multinational Enterprises or the UPM corporate website on upm.com/codeofconduct UPM CODE OF CONDUCT 5 OUR COMMITMENT OUR PEOPLE AND BUSINESS INTEGRITY OUR STAKEHOLDERS VOICE YOUR OPERATIONS CONCERNS 2. Respect people and human rights 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. 6 UPM CODE OF CONDUCT OUR COMMITMENT OUR PEOPLE AND BUSINESS INTEGRITY OUR STAKEHOLDERS VOICE YOUR OPERATIONS CONCERNS WHAT IS THE RIGHT THING TO DO? Contribute and engage others • 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. LEARN MORE UN Universal Declaration of Human Rights ILO Declaration on Fundamental Principles and Rights at Work UPM CODE OF CONDUCT 7 OUR COMMITMENT OUR PEOPLE AND BUSINESS INTEGRITY OUR STAKEHOLDERS VOICE YOUR OPERATIONS CONCERNS 3. Taking care of the environmental impact and product safety We comply with relevant environmental laws and pay close attention to how our operations impact the air, climate, water, land and biodiversity. We aim Reduce, to minimise our adverse effects, including how we use land. We continuously reuse, measure and assess the direct and indirect environmental loads and impacts of our operations and promote the use of advanced technologies. recycle! 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. 8 UPM CODE OF CONDUCT OUR COMMITMENT OUR PEOPLE AND BUSINESS INTEGRITY OUR STAKEHOLDERS VOICE YOUR OPERATIONS CONCERNS WHAT IS THE RIGHT THING TO DO? • 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). UPM CODE OF CONDUCT 9 OUR COMMITMENT OUR PEOPLE AND BUSINESS INTEGRITY OUR STAKEHOLDERS VOICE YOUR OPERATIONS CONCERNS 4. Zero-tolerance for corruption and bribery 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.
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