UPM-Kymmene Oyj

UPM-Kymmene Oyj has implemented a defined governance framework for its lobbying activities, with "UPM Public Affairs ... led by the Vice President, Public Affairs. He reports to the Executive Vice President of Marketing, Sustainability and Communications, who is a member of the Group Executive Team," and supplemented by "topic specific steering groups where our advocacy activities are steered, and these topics are reviewed in the Group Executive Team regularly," illustrating clear ownership and recurring oversight of its direct advocacy. The company also addresses indirect engagement by confirming that "UPM is a member of various joint industry, sustainability and trade associations and networks. This is one way of influencing and monitoring the policies for being aligned with our strategy and climate pledge," and stating that "UPM's engagement in trade associations and policy-related activities is globally based on this strategy, which ensures that all engagement is consistent with the overall climate change strategy," which indicates systematic alignment with its climate objectives. These arrangements demonstrate strong governance through structured processes and named accountable parties. However, the company does not disclose a dedicated audit or public report explicitly evaluating the alignment of its climate-related lobbying efforts or any third-party review of its lobbying governance, nor does it specify criteria for escalating or exiting associations whose policy positions diverge from its climate strategy.