Metsä Board Annual Review 2024

METSÄ BOARD Annual review 2024

S4 – Consumers and end-users

Health and safety The Code of Conduct includes the commitment to ensure product safety across the value chain. In addition to traceable wood fibre, Metsä Board’s other raw materials come from reliable suppliers, who are committed to complying with the Supplier Code of Conduct, and who meet the require- ments for product safety. Metsä Board complies with legislation protecting the health of people and the environment, such as the EU regulation on the registration, evaluation, authorisation and restriction of chemicals (REACH), the CLP Regulation on the classification, labelling and packaging of chemicals, leg- islation on the use of biocides, and product requirements concerning food safety. As a large share of Metsä Board’s paperboards are part of the food supply chain, the product safety practices in production are as stringent as those followed in the food industry. Metsä Board assures the safety of its products in compliance with the applicable legislation in its market areas in Europe, the Americas and Asia. The company’s mills follow good manufacturing practice (GMP), which is a requirement for the production of all food contact materials. All Metsä Board’s mills comply with the requirements of the ISO 22000 food safety system, and the mills producing paperboard for food contact have also been certified in accordance with the requirements of the FSSC 22000 food safety system. Contract entrepreneurs and suppliers are required to meet equal standards so that the cleanliness and safety of products for consumers and end-users can be ensured. The certified management systems of Metsä Board’s production units are listed in the table on page 97. Access to quality information To ensure the quality of product management, harmonised product management and product safety processes are in place. The processes encompass product specification, the management of basic information, product descriptions and compliance documents, and the management of product requirements of customers and officials throughout the product life-cycle.

customers, consumers and end-users is primarily the sales organisation’s responsibility. The observations from customer engagement are discussed at sales meetings and at meetings of Metsä Board’s management if required. Metsä Board’s management is responsible for taking consumers’ and end-users’ needs and expectations into account in decision-making.

Material impacts, risks and opportunities related to consumers and end-users

Business operations and value creation 2 This is Metsä Board 4 CEO’s review 6

Material sub-sub-topic

Impacts

Risks and opportunities for Metsä Board Management

Personal safety of consumers and end-users Health and safety

Risk: Metsä Board suffers reputational damage among current and poten- tial new customers, consumers and end-users, and may incur liabilities for compensation and other costs related to the limitation of damage. Risk: Metsä Board suffers reputational damage among current and poten- tial new customers, consumers and end-users, and may incur liabilities for compensation and other costs related to the limitation of damage.

If Metsä Board’s products were to exhibit defects related to product safety, there would be negative impacts on the health and safety of consumers and end-users.

• Metsä Board uses regular product safety surveys, inspections, risk assessments and monitoring. • Metsä Board has appropriate certified management systems.

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Strategy and financial targets

Value creation

Information-related impacts on consumers and end-users Access to quality information

Contacts from corporate customers, consumers and end-users are handled and directed to the appropriate party to ensure a comprehensive response. Contacts concerning product feedback are used in product or product portfolio analyses, and they are taken into account in product and service development. Any product complaints are investigated internally with the support of external parties such as research institutions if required. In accordance with the company’s process for managing quality deviations, root cause analyses are carried out for quality deviations, and any required corrective action is adopted. A standardised recall process is followed in the event of any product defects affecting consumer product safety to ensure that all products potentially harmful to health are removed from the market and transports. At the EU level, defects detected in food contact materials and related recalls are monitored and reported using RASFF (Rapid Alert System for Food and Feed) alerts. There were no product safety-related RASFF notifications concerning Metsä Board’s products or any recalls of consumer packaging made from the company’s paperboard in 2024. No incidents of non-compliance concerning the company’s marketing communications or product and service information and labelling were reported. Compliance and Ethics Channel Consumers and end-users can use Metsä Group’s Compliance and Ethics Channel to report any ethical concerns or non-compliance with legislation. The Compliance and Ethics Channel and the process for handling reports are described in greater detail under G1 – Business conduct . Actions In 2024, Metsä Board’s operations did not cause severe human rights impacts, and no confirmed severe human rights issues or human rights violations related to consumers and end-users were brought to the company’s attention. Metsä Board’s actions seek to mitigate negative impacts and produce positive impacts on consumers and end-users. As the actions are contin- uous and annual, no individual actions can be singled out in the reporting year or the coming years. Processes are developed in line with continuous improvement. Metsä Board has not identified significant operating or capi- tal expenditure allocated to actions concerning consumers and end-users.

If Metsä Board’s products were to include misleading product infor- mation, there could be negative impacts on the health and safety of consumers and end-users.

• Metsä Board has established practices for ensuring that its product information is up to date and accurate. • The compliance of product information is controlled annually and through continuous change monitoring. • Product information and product requirements are controlled with the product information management system, among other things.

Financial development 10 Key figures 12

Report of the Board of Directors

20 20 37 70 89 96

• Sustainability statement

Positive impact on the environment and society or on Metsä Board’s business Negative impact on the environment and society or on Metsä Board’s business

General information

E – Environment

S – Social responsibility

G – Governance

Targets Product safety, human rights and respect for the environment are impor- tant themes for consumers and end-users. Metsä Board has not yet set a 2030 sustainability target specifically related to consumers and end-users. The company’s internal targets and policies for ensuring the quality and compliance of operations and products have been defined in the Quality policy, the goals of which are described under Policies . The identification and assessment of material impacts, risks and opportunities The material impacts concerning consumers and end-users were identified in a human rights impact assessment, the results of which were included in the company’s double materiality assessment. The impacts, risks and opportunities concerning health and safety and access to quality information identified in the double materiality assessment are described in the table on page 86. Other impacts, risks and opportunities related to consumers were detected in the double materiality assessment. These are described under E1 – Climate change , E4 – Biodiversity and ecosystems and E5 – Resource use and circular economy . The assessment of human rights impacts and the materiality assessment are described on pages 26–28. Users of paperboard products for food contact are among Metsä Board’s key consumers and end-users. In terms of end use, food contact material accounts for a large share of Metsä Board’s sales. Product safety and accurate and easily available product information related to it are especially important in food contact end uses. The impacts are not sys- tematic but are most likely related to individual incidents such as defects in individual products.

Policies Sustainability related to Metsä Board’s consumers and end-users is guided by policies comprising Metsä Group’s Code of Conduct, Supplier Code of Conduct, Quality policy and management systems approved by the company’s Board of directors. The goal of policies is to minimise adverse environmental impacts, promote human rights and strengthen ethical operations, and thus demonstrate to consumers and end-users that the products are safe and sustainably produced. The policies indirectly encompass all consumer and end-user groups. In all its operations, Metsä Board respects internationally recognised human rights and in accordance with the UN Guiding Principles on Business and Human Rights, it is committed to rectifying any negative human rights impacts. In relation to consumers or end-users, no incidents of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO’s Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises have been brought to Metsä Board’s attention. The Code of Conduct and the Supplier Code of Conduct are discussed in more detail under S1 – Own workforce and S2 – Workers in the value chain . The Quality policy determines the targets and policies for ensuring the quality of Metsä Board’s operations and products. The goal is to ensure product safety, and that the quality of the company’s operations, products and services meets the needs and expectations of customers – and thus consumers and end-users. The Quality policy is owned by the President and CEO of Metsä Group, and its implementation at Metsä Board is the responsibility of Metsä Board’s Corporate Management Team.

Annexes to the Sustainability statement

98 Consolidated financial statements 102 Notes to the consolidated financial statements 150 Parent company financial statements 153 Notes to the parent company financial statements 166 The Board’s proposal to the Annual General Meeting for the distribution of funds 167 Auditor’s Report 171 Sustainability statement assurance report 173 Shares and shareholders 177 Ten years in figures 178 Taxes 179 Production capacities 181 Calculation of key ratios and comparable performance measures Corporate governance 183 Corporate governance statement 190 • Board of Directors of Metsä Board 194 • Corporate Management Team of Metsä Board

Engaging with consumers and end-users about impacts

As a rule, Metsä Board’s customers are companies that interact with consumers and end-users in accordance with their own processes. Metsä Board does not have a process for directly communicating with consumers and end-users. Consumers and end-users can contact Metsä Board directly using the contact form available on the company’s website. Product and customer feedback is handled by Metsä Board’s technical customer service in cooperation with production. Information about consumers’ and end-users’ wishes and needs is collected through active customer cooperation, market research and consumer surveys. Interaction is continuous and needs-based. Annual customer experience surveys are part of the evaluation of customer needs and the identification of development needs. Engagement with

196 Remuneration report 201 Investor relations and investor information

Report of the Board of Directors | METSÄ BOARD ANNUAL REVIEW 2024