Risk assessment forms the basis of our compliance program
Each business area, unit and function is responsible for identifying and managing its compliance risks. Annual and case-specific risk assessments guide our compliance activities and mitigation actions, which are updated throughout the year to reflect changes in the risk environment.
Policies and procedures document what is expected of all employees
The compliance system is embedded in our governance model and is designed to promote a culture of integrity at all levels. To remain relevant, we review the need to update policies and procedures annually as part of our policy management process.
Ongoing training and communication help us make the right choices
Our e-learning modules on policies and procedures are easily accessible to employees on a global e-learning platform, and completing these mandatory e-learning courses is a prerequisite for short-term incentive payments. Training is also extended to the employees of our business partners who work for UPM. Compliance e-learning modules are supported by tailored training and active communication.
Comprehensive monitoring helps us take action
Our monitoring activities are based on a risk matrix that considers country risk, complexity and the scale of our operations in each country. In addition, we conduct risk-based reviews on specific topics such as competition law or anti-corruption, and ongoing counterparty screening activities. Key findings and recommendations from compliance reviews are reported to the Audit Committee of the Board of Directors and to the businesses, and any necessary follow-up action is taken with the relevant business unit.
Response and remediation contribute to organizational justice
We encourage employees to report any misconduct or unethical behavior without fear of retaliation. We maintain procedures to investigate business conduct incidents in a timely, independent and objective manner.
Acting in compliance with sustainability
We integrate sustainability management and compliance with laws and regulations into our operations through international management systems and a compliance system. The UPM Sustainability Policy Statement and related standards and guidelines provide the basis for transparent, compliant, and third-party verified reporting at the group, site, and product levels.
Read more about managing sustainability
