Code of Conduct and Corporate Social Responsibility Policy

Fair competition

UPM commits to competing in the market in which it operates in a manner that is fully in line with competition regulations and that upholds a high standard of integrity and ethics.

Business Method

UPM is committed to its reputation of excellence, which is based on reliability, quality and punctuality. We fully comply with current Acts and Regulations and we are viewed as a trusted and respected business partner that upholds high standards of ethics as well as social responsibility throughout our business practices and we encourage all our partners, suppliers and associates to match our ethical standard in this regard.

Compliance with Laws

All UPM operations, protocols and codes of conduct fully comply with national and international applicable laws and regulations. Our conduct is aligned with the Ten Principles of the UN Global Compact as well as with the UN Declaration of Human Rights.

Improper Payments

UPM shall not offer, give, solicit, promise or receive any item or service of value directly or via a third party, as a means of influencing business actions to a corporate or public official or third party which would undermine his/her professional duties and integrity. UPM’s business practices are in line with Polish and international anti-bribery and corruption legislation, which includes the Polish Penal Act, the COE Criminal Law Convention and the UK Bribery Act.

Gifts, Hospitality and Expenses

UPM’s business practices are based on quality, integrity and competence. We do not provide or offer gifts, hospitality or expenses to our clients or our clients’ employees, associates or relatives, with the sole exception of promotional items that bear our company logo and do not incur a high cost. Hospitality connected to social events, meals or entertainment can be offered if consistent with generally accepted business practices, fulfils a valid business purpose and keeps to a reasonable budget. Any travel, accommodation or other related expenses incurred by the individual shall be covered by the client unless otherwise stipulated in writing prior to the event. Gifts, hospitality and expenses should have no business roles other than enhancing relations or promoting the giver’s company by incorporating a logo or message on a promotional item. They shall not be given or received in connection with business dealings such as contract bids, awards or evaluation.

Non-disclosure

UPM operates within the framework of a non-disclosure obligation. Our Non-disclosure obligation is enforced in order to ensure that sensitive information regarding UPM employees, business, commercial, technical, contractual or safety rules and other confidential information is not shared with unauthorized parties, which in turn could potentially harm the reputation and/or business activity of our company. The disclosure of any information protected by law is equally prohibited and our Non-disclosure obligation is a legally binding contractual agreement which prohibits the sharing of sensitive and/or confidential data with external parties by UPM employees and business partners throughout the duration of their contracts with UPM as well as after.

Conflict of Interest

Our conflict of Interest Policy refers to any case where an UPM employee’s personal, professional, financial or other similar types of interests could compromise or bias his or her professional judgement, loyalty and objectivity as a UPM employee or be perceived as such, therefore undermining UPM company values, business practice and reputation. This involves cases where a personal interest or business interest comes into play, economically or otherwise, directly or via someone related. Should UPM be made aware of a case of a potential conflict of interest, perceived or actual, UPM will contact the Client and parties involved as a matter of urgency.

Political activity

UPM takes on an apolitical stance and maintains political neutrality.

Equal treatment

UPM is committed to ensuring that all employees work in an environment that promotes respect for all individuals. We recruit talent on based on competence and skills regardless of gender, religion, ethnic background, age or culture. Our workplace celebrates diversity and inclusivity and all employees are guaranteed fair wages and a positive working environment where human rights are respected and upheld. Any behaviour or treatment that may be perceived as offensive, malicious, degrading or threatening including bullying, harassment or discrimination is deemed unacceptable at UPM.

Health, Safety and Environment (HSE)

UPM continuously strives to provide its employees with a health and safety culture that fosters health, safety and wellness in the workplace which is fully aligned with up to date applicable laws and regulations. UPM aims to manage workplace health and safety to the highest standard possible and utilizes top HSE management systems. UPM plays its part in the fight against global warming and environmental damage at every stage of our protocols and product development. We make every effort to reduce our emissions and energy consumption ensuring that energy efficiency is maintained and the production of harmful waste minimized. We reduce environmental impact in every way we can across all our business practices and act in full compliance with environmental laws and regulations including industrial wastewater discharge compliance.

Minimum Age of Labor

Our company does not employ any individual below the age of 16.

Forced Labor

UPM does not tolerate, engage in or support the employment of any person against his or her own free will, nor will any individual be required to lodge identity papers or deposits in advance of their employment contract. UPM adheres to international labour standards and does not employ anyone through any form of forced labour nor engage in any forced labour practices.

Freedom of Association & Right to Collective Bargaining

As a company we support our individual employees’ rights to freedom of association and to collective bargaining. We recognize our employees’ fundamental labour right to form and join workers’ organisations of their own choice with a view to promote their interests and to bargain freely with employers. Any UPM employees living and working in countries where such freedoms and rights are restricted UPM offers support and opportunities to improve and have a voice with regard to their employment situation.

Working Hours & Wages

UPM acts in accordance with applicable local laws regarding working hours and remuneration. All wages paid to employees are ensured to be fair and in line with local employment legislation.

Employment Practices

All UPM employees and hired professionals are treated with equal respect and fairness. No form of harassment in the workplace is deemed acceptable nor is discrimination based upon age, gender, religion, cultural or ethnic background or any other reason.

Minority Rights

UPM respects and acknowledges the rights, values, needs and integrity of indigenous people and minority groups that work directly for our company as well as those that work with us indirectly or as clients and associates. Appropriate action will be taken to prevent any unfair treatment of these groups in our business practices.

Security Resources

UPM undergoes a highly rigorous selection process of security contractors with a view to avoid human rights risks in countries that do not have proper regulation of security firms enforced.

Selection of Business Partner, Agents and other Intermediaries

UPM requires all business partners, associates, intermediaries and agents to adhere to the guidelines and principles outlined in this UPM Corporate Social Responsibility Policy.

Standards towards own Suppliers and Subcontractors

UPM calls on all its suppliers and subcontractors to implement the principles outlined in this UPM Corporate Social Responsibility Policy.