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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.
Code of Conduct