--- title: "UPM-Kymmene Beteiligungs GmbH and Nordland Papier GmbH issue statement on UPM's human rights strategy in Germany; LkSG compliance" sdDatePublished: "2026-08-28T07:08:00Z" source: "https://www.upm.com/siteassets/reporting-hub/sustainability-related-reports/german-supply-chain-due-diligence-act-policy-statement-2026---upm-english.pdf" topics: - name: "human rights" identifier: "medtop:20000592" - name: "law" identifier: "medtop:20000121" - name: "environmental policy" identifier: "medtop:20000423" - name: "business governance" identifier: "medtop:20000199" - name: "paper and packaging product" identifier: "medtop:20000326" locations: - "Espoo" - "Finland" - "Germany" --- UPM-Kymmene Beteiligungs GmbH and Nordland Papier GmbH issue statement on UPM's human rights strategy in Germany; LkSG compliance July 30, 2026 Statement on UPM’s human rights strategy under the German Supply Chain Act (v. 3) 1 Statement on UPM’s Human Rights Strategy under the German Supply Chain Act This statement (the “Statement”) has been issued by UPM-Kymmene Beteiligungs GmbH and Nordland Papier GmbH pursuant to Section 6 of the German Act on Corporate Due Diligence Obligations in Supply Chains of 16 July 20211 (the “Act”). The Statement was adopted by the respective managing directors of UPM-Kymmene Beteiligungs GmbH and Nordland Papier GmbH on July 30, 2026. UPM-Kymmene Beteiligungs GmbH is a fully owned subsidiary of UPM-Kymmene Corporation, parent company of the UPM group of companies (“UPM”), headquartered in Helsinki, Finland. Nordland Papier GmbH is a fully owned subsidiary of UPM-Kymmene Beteiligungs GmbH. At the end of 2025, the UPM group employed approximately 15.100 people worldwide. UPM contributes to the sustainable transformation of society with material solutions, utilizing renewable feedstock. UPM creates long-term value through an extensive portfolio of decarbonization solutions, advanced materials, renewable fibres and communication papers, collaborating with industries and brands worldwide. For more information on UPM’s business, please visit: Our businesses | A material solutions company UPM in Germany UPM operates in Germany through its businesses UPM Communication Papers, UPM Specialty Materials, UPM Adhesive Materials and UPM Biochemicals. At the end of 2025 UPM had a total of five sites and approximately 3000 employees in Germany. UPM Communication Papers is a producer of graphic papers, offering an extensive product range for advertising and publishing as well as home and office uses. UPM Specialty Materials produces packaging and label papers. UPM Biochemicals is currently building a plant in Germany that will offer solutions related to wood-based renewable biochemicals, replacing fossil-based raw materials. UPM Adhesive Materials creates labelling materials for branding and promotion, informational labels and labels with functionality. UPM’s commitment to respecting human rights and addressing environmental impact UPM’s strategy guides the company to achieve its 2030 sustainability targets and contribute to the UN Sustainable Development Goals (SDGs). UPM is committed to creating value using sustainable and renewable resources, reducing its own environmental footprint and enhancing its positive societal impact. 1 Gesetz über die unternehmerischen Sorgfaltspflichten zur Vermeidung von Menschenrechtsverletzungen in Lieferketten, Lieferkettensorgfaltspflichtengesetz, LkSG, vom 16. Juli 2021 July 30, 2026 Statement on UPM’s human rights strategy under the German Supply Chain Act (v. 3) 2 For more information on UPM’s strategy and commitment to sustainability, please visit: Strategy | A material solutions company ESG | A material solutions company Sustainability | A material solutions company UPM has codified its respect for human rights and addressing environmental impact in its Code of Conduct, latest updated in 2025, and Sustainability Policy Statement. Both are available in German and several other languages at: Code of Conduct | A material solutions company Sustainability Policy Statement | A material solutions company The procedures, priority risks and expectations regarding managing human rights and environment-related risks described in sections I to III below are implemented at the UPM group level and apply to the operations of UPM-Kymmene Beteiligungs GmbH and Nordland Papier GmbH. I. Description of the procedures 1. Risk management system The UPM compliance system is the risk management system used to manage UPM’s human rights and environment-related risks. The elements of the risk management system are described in the illustration below and discussed in more detail in the following paragraphs. UPM’s compliance system has been embedded in its governance model and is designed to bolster company performance and a culture of integrity at all levels. July 30, 2026 Statement on UPM’s human rights strategy under the German Supply Chain Act (v. 3) 3 2. Risk analysis in own operations UPM regularly assesses human rights risks at business area, function, and corporate level. This includes identifying actual and potential risks and impacts, evaluating their severity and likelihood, and prioritizing the most significant issues for action. Business areas and functions are responsible for identifying risks within their own operations and activities. Prioritization and finally determination of materiality of the risks is assessed in connection to UPM’s corporate salient human rights assessment. The procedure is integrated into existing management systems to the extent possible and applied in investment processes. Environment-related risks within the meaning of the Act in UPM’s own operations have been assessed based on the combination of a questionnaire and expert opinions pertaining to the use of mercury and persistent organic pollutants, waste containing said substances and transboundary shipments of waste. 3. Risk analysis in supply chain In terms of human rights and environmental due diligence in its supply chain, UPM has a risk-based approach that consists of various elements applied before and during the onboarding of new suppliers and monitoring of business partners. These elements include Know Your Supplier screenings, third-party sustainability assessments by Ecovadis, and the high sustainability risk supplier framework and process. July 30, 2026 Statement on UPM’s human rights strategy under the German Supply Chain Act (v. 3) 4 UPM’s high sustainability risk supplier framework and process has been established to identify and capture human rights and environmental risks in UPM’s supply chain. The framework provides visibility into the sustainability aspects of UPM’s supply base and offers insight into sourcing categories on human rights and environmental risks and UPM’s focus areas for risk prevention. The high sustainability risk framework evaluates sustainability-related risk based on the risks associated with the sourced commodity and the country risk of the suppliers’ location. Suppliers identified based on said criteria are subject to risk mitigation plans and activities. The country risk is defined based on a combination of the Transparency International's Corruption Perception Index, the United Nations' Human Development Index, and the Environmental Performance Index. Commodity and industry specific environmental and social risks are evaluated in UPM's supply chain ESG risk saliency process in collaboration between responsibility and sourcing functions. Risk assessments can extend to several tiers, especially when commodities originate from forestry, agriculture and mining. Moreover, UPM supplier requirements, relating to certifications, for example, contribute to effective risk analysis. They are described in more detail in paragraph 5 ii below. 4. Preventive measures in own operations All UPM employees receive training in the UPM Code of Conduct. The Code of Conduct training addresses the protection of human rights and the environment, and the identification of risks relating to human rights and the environment. In addition, there is a separate e-learning on the requirements of the UPM Supplier and Third-Party Code for UPM employees dealing with suppliers. The connection between human rights violations and corruption is also handled in UPM’s anti-corruption training, which is mandatory for all salaried employees. The UPM Sourcing function arranges additional training for its personnel on responsibility principles and supplier requirements. Furthermore, based on the human rights due diligence process in own operations described in paragraph 2 above, mitigating actions and controls are defined at the business area or corporate level to verify compliance with UPM’s human rights approach. July 30, 2026 Statement on UPM’s human rights strategy under the German Supply Chain Act (v. 3) 5 5. Preventive measures vis-à-vis direct suppliers i. UPM Supplier and Third-Party Code Before entering a contract with a supplier, UPM requires that the prospective supplier is committed to the UPM Supplier and Third-Party Code or to similar standards defined in the supplier’s own code of conduct or other company policies. Section 2 of the UPM Supplier and Third-Party Code addresses respecting human rights, while section 3 covers environmental impacts. The UPM Supplier and Third-Party Code defines the minimum level of performance required from UPM suppliers. UPM requires its suppliers to ensure that their suppliers and sub-contractors providing products or services connected to the agreement between the supplier and UPM also comply with the UPM Supplier and Third- Party Code or similar standards. The UPM Supplier and Third-Party Code is adopted by the UPM Group Executive Team and has latest been updated in 2024. In addition, UPM published a “Practical guide to everyday decisions”, which summarizes the requirements of the UPM Supplier and Third-Party Code and UPM’s position on the topics covered and provides examples and good practices for implementation. UPM Sourcing co-operates continuously with suppliers to ensure compliance with the UPM Supplier and Third-Party Code. The UPM Supplier and Third-Party Code and the practical guide are available in 6 languages at: UPM Supplier and Third-Party Code | A material solutions company ii. Other preventive measures For suppliers identified in the high sustainability risk scope, additional risk-mitigating measures, such as audits or assessments (e.g. Ecovadis) can be used. Moreover, all wood and pulp sourced by UPM is either FSC™- or PEFC-certified (FSC N003385, PEFC/02-44-41), or it complies with the FSC Controlled Wood standard or Due Diligence requirements for PEFC. FSC Controlled Wood requirements include wide criteria related to the legality of the wood, respecting social and traditional rights (incl. the rights of indigenous and tribal peoples) and safeguarding areas of high conservation value. For more information on our supplier requirements, please see: Requirements | A material solutions company UPM monitors its business partner portfolio, including suppliers, against several official data sources using an automated screening tool. In the event of an alert, actions are taken to investigate and, if necessary, prevent or mitigate the identified risk. A supplier’s commitment to the UPM Supplier and Third-Party Code includes a requirement to permit UPM to verify compliance with the UPM Supplier and Third-Party Code through dialogue and, if considered necessary by UPM, through on-site audits. July 30, 2026 Statement on UPM’s human rights strategy under the German Supply Chain Act (v. 3) 6 Supplier audits and assessments are used to verify a supplier’s compliance with UPM’s supplier requirements, including the UPM Supplier and Third-Party Code. Supplier audits are regularly conducted by external auditors or UPM’s internal qualified auditors. UPM is a member of the Together for Sustainability (TfS) initiative, which has established an approach for evaluating and improving the sustainability performance of suppliers in the chemical industry. UPM uses TfS audit reports to further assess the human rights and environmental supplier risks and to improve the coverage of its risk assessments. The share of suppliers who are committed to the UPM Supplier and Third-Party Code and the coverage of supplier audits and assessments are monitored via the annual follow-up of UPM’s Group level responsibi