Do What s Right Stora Enso s Code of Conduct.

Dear colleague, In our transformation to a renewable materials growth company, we will face new demands and challenges, new markets and even new dilemmas. This makes our Code of Conduct more important than ever to keep us on a straight path. True to our value Do What s Right, our growth should be based on honesty, transparency and ethics. We promote diversity of thought and sustainable environmental performance, as well as the safety, health and well-being of our people. Our Code of Conduct is for everyone, everywhere, every day, and no exceptions. It is a natural part of our daily work. Making a safety observation, turning off the lights after work, or avoiding excessive customer entertainment, these are just a few examples of how we can live our values. And this is very much a part of our moving to being a value-driven company that means that it is not primarily the rules that drive our behavior, but our values. There will be times when a decision is difficult and complicated, resulting in conflicts with our business agenda, or even with your manager or colleagues. I urge you to read this carefully and follow the Code of Conduct with pride. If you are ever uncertain, ask before you act. Kalle Sundström Chief Executive Officer 3

This is the company you work for. Responsible business. We comply with all applicable local, national and international laws, regulations and voluntary commitments wherever we do business. We conduct business transactions with the best interests of Stora Enso in mind. We show zero tolerance for corrupt activities of any kind, either in our own operations or when we work with partners. We support free and fair competition by never becoming involved in pricefixing, market sharing or other anti-competitive practices. We take care of the company s valuable property and safeguard confidential information. We communicate with our stakeholders clearly and promptly. We listen to all our stakeholders and seek to engage with them constructively. Caring for people. We respect, support and fully observe international human and labour rights. We promote diversity of thought. We are a responsible neighbour. We take responsibility for the safety, health and well-being of our people. Caring for the environment. We continually improve our environmental performance. We actively work to improve our energy efficiency and reduce our dependence on fossil fuels. We use water responsibly. We manage forests responsibly and strive to conserve biodiversity. 4

This is your business Working for Stora Enso means you must be committed to these same policies in everything you do in your everyday work. These goals must guide all your tasks and decisions at work. This also means that if you see somebody else breaking these policies, you have a responsibility to report on them. These obligations are explained in more detail in this booklet. 5

6 Responsible business.

We comply with all applicable local, national and international laws, regulations and voluntary commitments wherever we do business. Obeying local laws and regulations is of the utmost importance. As a global company, there are many different laws and regulations we need to follow. You are responsible for obeying all of those controls that apply to your work, as well as our own company policies. Where local laws or regulations differ from our Code of Conduct, we have to make sure that we meet both standards. It is also our policy to require all agents, consultants and business partners who work on Stora Enso s behalf to comply with these same laws and practices, including Stora Enso Supplier s Code of Conduct. If you have any questions, please ask your supervisor or Legal for advice. 7

We conduct business transactions with the best interests of Stora Enso in mind. We must avoid all kinds of conflict of interest. A conflict of interest is when you are involved in something personally that could influence your work for Stora Enso and make it difficult for you to make decisions in the best interest of Stora Enso. When you are working on behalf of Stora Enso you must never be influenced by personal considerations or relationships. Don t: take on an outside job that could conflict with your job at Stora Enso, or work for a current or potential competitor, supplier or customer of Stora Enso. make a contract with a business that is managed or owned by a member of your family. buy properties or shares of companies that Stora Enso may have an interest in purchasing. act as a corporate director, officer or consultant of another company without the permission of your supervisor (this does not cover your involvement in any non-profit or charitable organisations). acquire or hold onto any interests in companies who are Stora Enso s suppliers, customers, potential customers or competitors. The above two restrictions do not prohibit you from owning insignificant stakes in a company or fund where you as an owner have no possibility to influence the operations of the company involved. 8

We show zero tolerance for corrupt activities of any kind. We compete vigorously, but always in compliance with the relevant anti-bribery laws. It is also our policy to require all agents, consultants and business partners who work on Stora Enso s behalf to comply with these same laws and practices. Non-compliance with anti-bribery legislation can have serious legal consequences for Stora Enso and the individuals involved. We neither take nor give bribes! It is also important to remember that offering or accepting gifts, hospitality, or expenses payments is prohibited if they are of unreasonably high value, or could inappropriately affect business transactions. Stora Enso always pays the travel and accommodation expenses of the company s own personnel. What kinds of gifts or hospitality are reasonable? Gifts or hospitality must comply with any applicable laws. Gifts or hospitality must never consist of cash or cash equivalents. Gifts or hospitality should not be offered in ways that make recipients feel that the giver expects something in return. Gifts or hospitality should be given and accepted openly in front of others, to make it clear that there is nothing to hide Gifts or hospitality should not be extravagant, excessive in value, or offered too often. Normal business courtesies such as paying for a meal or sharing a taxi may be considered as reasonable hospitality. 9

We support free and fair competition by never becoming involved in price-fixing, market sharing or other anti-competitive practices. Stora Enso is committed to free and open competition on the market. It is better for everyone if every business is able to work openly without illegal or unfair restrictions. We believe every company should be able to trade and compete with us as they wish, as long as they follow local laws and regulations just as we do. We remain resolved never to be involved in fixing prices artificially high or low, in the sharing of confidential information that gives another company an unfair advantage, or in any other unfair or restrictive business practice. Infringements of competition laws do not only violate our own Code of Conduct; they can also result in large financial penalties, criminal charges and even prison sentences for the individuals involved. Do: learn about local competition laws. ask for legal advice if you are uncertain about any practice. follow the rules in our Business Practice Policy when visiting mills, meeting competitors or conducting benchmark assessments. Don t: make any agreements with competitors without taking legal advice. agree with our competitors on price fixing, output levels, marketsharing or customer allocations. enter into exclusive long-term selling or purchasing agreements without legal advice. discuss market-related issues with our competitors. 10

Take care of the company s valuable property and safeguard confidential information. As an employee of Stora Enso, you ll often use computers, mobile phones, applications and other equipment and systems that are vital to the company. These valuables belong to the company, so use them and take care of them as you would your own personal possessions. Confidential and sensitive information is also of great value to Stora Enso. Examples include business plans, product specifications, technical details of methods and processes, client and customer lists, and financial information. It can harm Stora Enso if such confidential or sensitive information is shared with outsiders. Never use such confidential information for your personal gain. Working for Stora Enso means that you are in a position of trust. Treat any confidential or sensitive information you learn in your job with absolute confidentiality. 11

Do: consider carefully what you say or write when representing Stora Enso. respect copyrights and laws against discrimination, defamation etc. follow our security rules on confidential information. use company money and equipment efficiently and solely for business purposes. Don t: install unauthorised software on company equipment. use company equipment for any unauthorised purposes. Tips on how to avoid the accidental disclosure of confidential information: Do not discuss confidential business matters in public places such as trains, airplanes, restaurants, bars and hotel lobbies. Encrypt confidential emails and confidential information stored on memory sticks, servers or WeShare. Do not leave confidential documents on your desk overnight or when leaving your room for a longer period. Apply to become a Confidential Information User within Stora Enso so you can be given the security tools you may need to handle confidential information. To become a Confidential Information User, visit the Secure User site on WeShare. 12

We listen to all our stakeholders and seek to engage and communicate with them constructively, clearly and promptly. Clear and timely communications help other people to understand and trust us. Everything our company writes or says, whether internally or externally, must be honest, reliable and responsible. We must also invite others to give their point of view, particularly if it is different to ours. Information that we publish about Stora Enso must follow the rules and regulations of stock markets and financial reporting, so it is important to understand these rules. We must release company information promptly at the same time to all stakeholders, including stock exchanges and the media. Our main corporate spokespersons are the CEO and the heads of Communications and Investor Relations. Heads of business areas, subsidiaries, staff units, national organisations and mills are spokespersons within their own areas of responsibility. Spokespersons are appointed to speak on behalf of Stora Enso. They make the necessary judgments concerning the messages to be delivered and the channels to be used for the company s stakeholder dialogue, in line with the rules and regulations that govern Stora Enso. Do What s Right App To make these rules more accessible, we have designed the Do What s Right App, a portable Swiss Army knife for this Code of Conduct, Stora Enso s Business Practice Policy, Third Party Guidelines and more. We have incorporated the most popular compliance topics, most frequently asked questions, most common mistakes, and answers directly from our policies. It also makes the grievance channel easier to use, just a single click, and you can email or even call our Do What s Right hotline in an instant. To access the app from your smartphone, smart tablet or computer, go to https://dowhatsright.storaenso.com/ and follow the instructions. 13

14 Caring for people.

We respect, support and fully observe international human and labour rights. We want to ensure that all our employees share the same internationally recognised human and labour rights. We do not discriminate against any employee on the grounds of their racial or ethnic background, age, gender, disabilities, sexual orientation, religious beliefs, political opinions, family status, social origins or other such characteristics. We do not tolerate any form of harassment including violence, sexual harassment, punishment or abuse of any kind. We do not allow forced or child labour. Our employees have the right to organise themselves, join associations and bargain with the company collectively. We are a responsible neighbour. We respect the cultures, customs and values of local people and societies in the many different regions where we operate. We strive to contribute to positive social and economic development and minimise any negative impacts of our operations. We also build relationships with local communities wherever we work to build up mutual understanding. We do this by actively participating in dialogues with local stakeholders and by making local, national and global partnerships. 15

We promote diversity of thought. We know we are stronger when our workforce includes people of different backgrounds and cultures. Building diverse teams is a priority for us. We take responsibility for the safety, health and well-being of our people. A company performs better when its workforce is healthy and happy. Stora Enso promises all employees a workplace that is safe, healthy and fair, in line with internationally recognised human and labour rights. Employees are entitled to know their rights and ensure they are observed. 16

Do: respect other people s points of view. build teams of individuals with different backgrounds and skills. question policies, behaviour or actions that do not seem right. When in doubt, contact your supervisor, Human Resources or Legal (details at the end of this booklet). Safety tips: Study the relevant job safety regulations and risk assessments before you start work. Make sure you get the right safety training for your job. Follow all safety instructions and recommendations. Always wear the right safety equipment. Immediately report on any unsafe conditions or practices you notice. Give positive feedback on any practices you feel will enhance safety. Report any misconduct or situations where an accident nearly occurs, as well as actual accidents. Most importantly: always think before you act. Travel tips: Only use our official company travel agencies, corporate cards, airlines, hotels and car rental agencies. When travelling to a new country, find out about any special security or health issues you may need to consider. Make sure your vaccinations and other medications are up-to-date. Only use drivers provided by our company, a hotel transport service or an official taxi service, and always wear a safety belt. 17

18 Caring for the environment.

We continually improve our environmental performance. To achieve continual improvements in our environmental performance, we have to understand the potential environmental impacts of all our operations and activities, set improvement targets, take the necessary steps to reach these targets, and monitor our progress. It is important that everyone should understand their own roles and responsibilities with regard to environmental issues, in order to make the right decisions. Do: be aware of and consider the potential impacts of your work on the environment, and discuss unclear issues with your supervisor. play your part to reduce and minimise all kinds of polluting emissions. respect our neighbours and the environment around your workplace. use resources efficiently and reuse and recycle materials whenever possible to minimise waste. 19

We actively work to improve our energy efficiency and reduce our dependence on fossil fuels. The preferability of wood our main raw material over materials based on fossil fuels is a competitive advantage for us. Our products have comparatively low carbon footprints, and they also store carbon throughout their usage, after which they are recyclable or may be incinerated to produce energy. We expect all employees to contribute to our efforts to save energy. 20

We use water responsibly. We expect all our employees to help us save water, especially in regions where water is scarce. All Stora Enso units should regularly evaluate local watershed conditions and whenever necessary initiate cooperation with local stakeholders to bring about improvements. We manage forests responsibly and strive to conserve biodiversity. Forests are our most important partner and we expect all of our employees who work with forests to respect forests. We are committed to sustainable forestry and the conservation of biodiversity. Our employees must follow our policies and guidelines related to responsible forestry. 21

22 This Code of Conduct is for everyone, everywhere, every day.

No matter who you are, where you are, or what you do within Stora Enso, you must observe this Code of Conduct every day. There are no exceptions to this rule. This Code of Conduct concerns everything we do at Stora Enso. It has been designed to cover our activities all around the world, and there should never be any reason to break it. Because we believe that this Code of Conduct is vital to the future of Stora Enso, we will take an active and open approach to its observance. We will not accept rules being broken. Stora Enso will enforce this Code of Conduct by investigating any reports of rules being broken. Where infringements are proven, actions will be taken to prevent this happening again. This process will be full and fair for everyone involved. We will ensure confidentiality for anyone reporting violations. Whistle-blowers will not be fired, suspended or discriminated against for the mere reason of blowing the whistle. Correspondingly, action will not be taken against anyone accused of wrongdoing before an accusation has been duly investigated. If it is established that the Code of Conduct has been broken, Stora Enso may take disciplinary action, and in serious cases even terminate employment agreements. 23

Our partners must also follow this Code of Conduct. We also require all agents, consultants and business partners who work on Stora Enso s behalf to comply with these same laws and practices, including Stora Enso Supplier s Code of Conduct. 24

Who to report to if you think somebody is breaking these rules. If you have any questions about this Code of Conduct and related policies and guidelines: Contact your own supervisor first, or send your questions to: codeofconduct@storaenso.com (please note that this email should only be used for asking questions, not reporting misconducts.) If you see or suspect misconduct make a report immediately. To make a report, we encourage you to speak directly to your own supervisor, Human Resources or Legal. You can also report your concerns anonymously in confidentiality to the Head of Internal Audit. Address: Head of Internal Audit, Stora Enso Oyj, P.O. Box 309, FI-00101 Helsinki, Finland. If this is not possible, you may alternatively report certain concerns, particularly on topics such as suspicions of bribery or financial wrongdoing through Stora Enso s confidential reporting line Do What s Right. Do What s Right Hotline Do What s Right can be contacted on the Internet, by e-mail or by telephone 24 hours a day, 7 days a week. For more information on this service see: www.storaenso.com/dowhatsright 25

Ask before you act. It s important that you fully understand the Code of Conduct and what it means for you. You must take responsibility for learning the rules and ensuring that they are followed everywhere you work. If you need more information or advice on the Code of Conduct, don t hesitate to get in touch with someone who can help you. Such people include your own supervisor, Human Resources contacts or Legal. This Code of Conduct is a summary of the key ethical policies, principles and guidelines relating to Stora Enso s operations. The company s official policies and guidelines can be read in full on weshare. www.storaenso.com/codeofconduct Note that certain jobs within Stora Enso are covered by further specific policies and guidelines that need to be understood in addition to the rules set out in this Code of Conduct. 26