We are committed to compliance with the UPM Code of Conduct and applicable laws and regulations. We strive to ensure compliance by training employees, by raising awareness through active communication and by developing our risk management, monitoring and reporting processes.
Compliance
Responsibility is one of our strategic focus areas and compliance is an integral part of it.
Our compliance system is embedded in our governance model and is designed to support company performance and a culture of integrity at all levels. The main emphasis of the system is on preventive actions, which are based on the annual risk management cycle and risk assessments conducted in all businesses and operations.
UPM compliance system
Responsibility for compliance
Responsibility for compliance extends from the Board of Directors to every UPM employee.
| Board of Directors | Approves company values and corporate policies and monitors compliance therewith |
| Audit Committee | Assists the Board in monitoring compliance by reviewing quarterly assurance and compliance reports |
| President and CEO | Top-level commitment, manages and oversees the company’s daily business operations |
| Group Executive Team | Top-level commitment, assists the President and CEO with the approval and execution of group-level rules and procedures |
| Business Area Boards | Top-level commitment, implementation of group-level rules and procedures in businesses, review of risk management and assurance |
| Strategy Team | Integrates integrity and responsibility in company strategies |
| Ethics Advisory Committee | Oversees investigation of alleged misconduct and provides advice on remediation actions |
| Disclosure Committee | Assesses compliance with applicable disclosure requirements |
| Assurance Committee | Co-ordinates quarterly group-level assurance reports and oversees compliance with applicable financial reporting requirements |
| Head of Internal Audit | Maintains the company’s Report Misconduct channel, conducts investigations and reports quarterly to the Audit Committee |
| Chief Compliance Officer | Owns the UPM Code of Conduct, oversees the compliance system and manages legal compliance programmes, and reports quarterly to the Audit Committee |
| UPM employees | Make the right choices in everyday work |
| Auditor | Provides quarterly assurance reports to the Audit Committee, semi-annual assurance reports to the Board of Directors and an annual Auditor’s Report to the shareholders |
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You may report your complaints or concerns relating to violations of the UPM Code of Conduct, any policies or rules thereunder or any applicable laws or regulations to the Head of Internal Audit, Chief Compliance Officer and Security Director through this channel.
