UPM has committed to abiding by the values and principles defined in The Corporate Social Responsibility Policy and the Code of Conduct. We have managed to ensure a sufficient level of protection and security through our methods and business practice, thus fostering a working environment in which every employee is treated with fairness, equality and respect.

In order to foster a friendly work environment at UPM, we oblige each and every one of our employees to abide by these rules. We do however acknowledge that in our daily working lives we can come across all sorts of situations and we call on all our employees to resist adopting inappropriate approaches and/or methods wherever possible.

UPM has implemented an internal reporting process regarding frauds and irregularities with a view to meeting our employees’ expetations. Our reporting process is confidential and we recommend that:

• Any observed suspicious findings and/or irregularities are to be urgently reported to your line manager in order to counteract them with immediate effect;
• If an employee feels as though he or she is unable to counteract these findings for whatever reason the matter should be escalated to senior management immediately;
• In situations where there are objections to the above, UPM offers employees the support of an impartial fraud team which can be approached in full confidentiality.

Full confidentiality of the reports and data submitted in this sort of situation are guaranteed by UPM, along with the anonymity of the person(s) submitting the report and any applicants, even if it turns out to be unfounded or submitted in error. It is equally possible to submit these reports by name, should anonymity not be considered necessary, however both methods of submission will be considered equally important in the eyes of the firm and will be handled on a case by case basis.

UPM ensures full protection to:

1. The person of the applicant;
2. The person about whom the application was sent;
3. The person dealing with the verification process of the validity of the case reported.

The above person(s) will remain fully protected by UPM from any retaliatory moves, sanctions, threats or discriminatory treatment of any sort as a result of reporting the above situations to UPM senior management.

The guidelines of this Policy do not affect in any way nor limit the obligation and the option of reporting irregularities to the relevant competent judicial, supervisory or regulatory authorities in Poland and countries in which UPM is performing its business operations, as well as the obligation to notify internal control authorities at UPM.