This Code of Conduct has been approved by the UPM Board of Directors on 31 May 2006, and amended on 3 August, 2010.
UPM’s objective is to pursue long term profitable business in an ethical and responsible manner taking into account economic, human and social, as well as environmental matters.
Striving towards sustainable development and continuous improvement are part of the everyday way of operating at UPM. UPM's Code of Conduct, leadership principles and values create the frame for the way of working and underline UPM's commitment to responsible business practices. UPM's values are Trust and be trusted, Achieve together, and Renew with courage.
The Code of Conduct defines the way of operating for all UPM employees including directors and officers without exception. It is complemented as needed by more detailed rules and guidelines approved by the Group Executive Team, UPM Business Groups and Business Areas and functions. All company rules and guidelines have to be in full compliance with the UPM Code of Conduct.
Legal Compliance and Disclosure
It is the policy of UPM to comply in all of its operations with applicable laws and regulations wherever it conducts its business. These include, among others, laws and regulations related to securities markets, corporate governance, competition, product safety and product liability, occupational health and safety, labour, environment, protection of intellectual property, protection of individual privacy and equality at work.
As a listed company UPM is committed to compliance with its obligations under the listing rules of NASDAQ OMX Helsinki Ltd and other applicable rules. Accordingly it is UPM’s policy that all reports and documents it files with relevant governmental and regulatory agencies as well as communications to its investors and other stakeholders contain information which is accurate, complete and based on verified facts giving a materially correct picture of the company’s operations. Such information will be fairly and promptly disclosed to the public.
Irrespective of position, no one at UPM has the right to expect or allow illegal activities
Conflicts of Interest, Gifts and Bribes
UPM employees are expected to promote the interest of UPM and in doing so act responsibly.
UPM prohibits any corruption or bribery in its operations. UPM and its employees will not pay or offer to pay bribes or illegal payments.
Employees are prohibited from taking personal benefits from opportunities discovered through the use of corporate position or information. UPM employees must avoid activity which leads to a conflict of interest. This includes giving and accepting personal gifts or benefits beyond reasonable hospitality given in the ordinary course of business. Conflicts of interest would arise if an employee or his or her family member receives improper personal benefit as a result of the employee’s position in UPM. Apart from receipt of cash, items of nominal value (a maximum of 100 euros) are excluded. UPM employees must also not compete with UPM. The Company does not support political candidates, parties or groups.
All employees are expected to take proper care of UPM’s assets, use them efficiently and not to use them for any unauthorized purposes
Disclosing of confidential customer and other information to any outside party or the use of such information in conflict with UPM’s interests is prohibited without exception.
Respecting and Promoting Human Rights
UPM respects the universal human rights as defined by the United Nations’ Universal Declaration of Human Rights in its own operations and promotes their implementation in its sphere of influence. Among those rights which the Company views as fundamental and universal are: freedom of thought, opinion, expression, religion and to peaceful assembly as well as freedom from any discrimination based on race, age, nationality, gender or sexual orientation.
The Company does not tolerate the use of forced or child labour.
Human Resources Practices
All employees with managerial duties are required to actively and purposefully promote a leadership culture that is in accordance with UPM’s values and the spirit of this Code of Conduct.
UPM strives to provide a safe and inspiring working environment to all employees. All employees are required to conduct their duties without endangering work safety. The company encourages its employees to engage in their own personal and professional development and growth. UPM is committed to treating all employees fairly, impartially and equally.
UPM is committed to equality of opportunity in all its employment practices, policies and rules.
Environmental Practices
UPM’s environmental management is based on internally defined goals, measuring the realization of these as well as on developing and implementing best practices in the whole supply chain.
UPM measures and assesses continuously both the direct and the indirect environmental loads and impacts of its operations and strives to manage these systematically in accordance with the principle of continuous improvement. The environmental loads and impacts related to product lifecycle result from sourcing raw materials, production, distribution of products, and their recovery and disposal.
UPM assesses its suppliers systematically and regularly also from the perspective of social and environmental responsibility.
IMPLEMENTATION OF THE CODE OF CONDUCT
All UPM employees must comply with this Code of Conduct. Employees are encouraged to contact supervisors, managers or other appropriate personnel when in doubt about the best course of action in a particular situation.
UPM strives to ensure compliance with this Code of Conduct by developing the Company’s auditing, monitoring, and reporting processes.
Employees who violate this Code are subject to disciplinary action up to and including termination of employment. Employees are required to report any possible violations against this Code to their own superior or to the Internal Audit function. UPM has also an electronic channel and a physical mailing address, both available on UPM’s intranet and website, through which concerns and issues can be confidentially and anonymously addressed to the head of UPM’s Internal Audit function.
Any person(s) reporting such violations are not to be retaliated in any way for making such a report. In all instances the rights and privacy of both the reporting person(s) and the one(s) accused of violations are to be adequately protected and assured.
Any waiver of the Code of Conduct for executive officers and directors may be made only by the Board of Directors or a Board Committee and must be promptly disclosed to shareholders.