Metsä Board Oyj

S1 Engaging with own workers and workers’ representatives about impacts

S1-2 – Processes for engaging with own workers and workers’ representatives about impacts

S1-3 – Processes to remediate negative impacts and channels for own workers to raise concerns

S1 Processes to remediate negative impacts and channels for own workers to raise concerns ;

G1 Mechanisms for identifying, reporting and investigating concerns

S1-4 – Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

S1 Actions

S1-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

S1 Metsä Board’s 2030 sustainability targets ;

S1 Employee head count by gender -table;

S1-6 – Characteristics of the undertaking’s employees

S1 Employee head count by country -table;

S1 Employees by contract type, broken down by gender -table;

S1 Employees by contract type, broken down by country -table;

S1 Employee turnover and recruitment -table;

S1-7 – Characteristics of non-employee workers in the undertaking’s own workforce

S1 Non-employee workers in own workforce -table;

S1 Engaging with own workers and workers’ representatives about impacts ;

S1-8 – Collective bargaining coverage and social dialogue

S1 Policies ;

S1 Collective bargaining coverage and advocacy -table

S1-9 – Diversity metrics

S1 Gender distribution at top management level -table;

S1 Distribution of employees by age group -table;

S1-10 – Adequate wages

S1-11 – Social protection

S1 Social protection -table;

S1-12 – Persons with disabilities

Non-material. Most Metsä Board employees are production workers with specific limitations regarding disabilities. It was assessed that there is no need to discuss disabilities separately from other diversity matters in Metsä Board's case.

S1-13 – Training and skills development metrics

S1 Training and skills development -table

38

Report of the Board of Directors | Metsä Board Annual review 2025

ESRS INDICATOR

LOCATION & COMMENT

S1-14 – Health and safety metrics

S1 Policies ;

S1 Actions ;

S1 Health and safety -table;

S1-15 – Work-life balance metrics

S1 Policies ;

S1 Family-related leave -table;

S1 Total remuneration ratio of women and men -table;

S1-16 – Compensation metrics (pay gap and total compensation)

S1 Total remuneration -table;

S1 Incidents, complaints and severe human rights impacts ;

S1-17 – Incidents, complaints and severe human rights impacts

S1 Incidents, complaints and severe human rights impacts -table;

ESRS S2 – Workers in the value chain

S2-1 – Policies related to value chain workers

S2 Engaging with value chain workers about impacts

S2-2 – Processes for engaging with value chain workers about impacts

S2-3 – Processes to remediate negative impacts and channels for value chain workers to raise concerns

S2 Processes to remediate negative impacts and channels for value chain workers to raise concerns ;

G1 Mechanisms for identifying, reporting and investigating concerns

S2-4 – Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions

S2 Processes to remediate negative impacts and channels for value chain workers to raise concerns ;

S2 Actions

S2-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

S2 Targets ;

S2 Reporting principles for metrics ;

G1 Metsä Board’s 2030 sustainability targets ;

G1 Reporting principles for metrics

ESRS S3 – Affected communities

S3-1 – Policies related to affected communities

S3 Policies

S3-2 – Processes for engaging with affected communities about impacts

S3 Engaging with affected communities about impacts

S3-3 – Processes to remediate negative impacts and channels for affected communities to raise concerns

S3 Processes to remediate negative impacts and channels for affected communities to raise concerns ;

G1 Mechanisms for identifying, reporting and investigating concerns

S3-4 – Taking action on material impacts on affected communities, and approaches to managing material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions

S3 Processes to remediate negative impacts and channels for affected communities to raise concerns ;

S3 Actions

S3-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

S3 Targets

ESRS S4 – Consumers and end-users

S4-1 – Policies related to consumers and end-users

S4 Policies

S4-2 – Processes for engaging with consumers and end-users about impacts

S4 Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

S4-3 – Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

S4 Processes to remediate negative impacts and channels for consumers and end-users to raise concerns ;

G1 Mechanisms for identifying, reporting and investigating concerns

S4-4 – Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

S4 Processes to remediate negative impacts and channels for consumers and end-users to raise concerns ;

S4 Actions

S4-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

S4 Targets

ESRS G1 – Business conduct

G1-1– Business conduct policies and corporate culture

G1 Policies ;

G1 Mechanisms for identifying, reporting and investigating concerns

G1-2 – Management of relationships with suppliers

G1 Management of relationships with suppliers ;

G1-3 – Prevention and detection of corruption and bribery

G1 Mechanisms for identifying, reporting and investigating concerns ;

G1 Prevention and detection of corruption and bribery

G1-4 – Confirmed incidents of corruption or bribery

G1 Mechanisms for identifying, reporting and investigating concerns ;

G1 Incidents of non-compliance with good governance or ethical corporate culture -table

G1-5 – Political influence and lobbying activities

G1 Political influence and lobbying activities

G1-6 – Payment practices

Non-material

39

E – Environment

The EU Taxonomy

General

The Taxonomy is a classification system for the financial market based on Regulation (EU) 2020/852, valid as of the beginning of 2022, listing economic activities sustainable in terms of climate and the environment. The goal of the Taxonomy is to channel money to sustainable investments so that the EU can achieve the ambitious emissions reduction targets it has set for itself.

The European Commission has adopted Delegated Regulation (EU) 2026/73, which simplifies EU Taxonomy reporting, for example by introducing a materiality concept and new reporting tables. Metsä Board applies the new Delegated Regulation in its 2025 Taxonomy reporting. Comparative figures have not been restated.

The Taxonomy does not currently include technical screening criteria for Metsä Board’s main business operations, the paperboard and market pulp businesses.

Taxonomy reporting

The Taxonomy defines six main environmental objectives against which the company’s different economic activities are assessed. These environmental objectives are: (a) climate change mitigation; (b) climate change adaptation; (c) sustainable use and protection of water and marine resources; (d) transition to a circular economy; (e) pollution prevention and control; and (f) protection and restoration of biodiversity and ecosystems. Taxonomy-eligible activities have been assessed against the environmental objective to which each activity contributes most substantially. In addition, an assessment has been made to determine that the activities do no harm to any other environmental objectives. In the Taxonomy, business disclosures include the share of sales, capital expenditure and operating expenditure.

The taxonomy-aligned disclosures indicate how the economic activity supports the environmental objectives. An economic activity is considered taxonomy-aligned if it contributes substantially to one of the defined environmental objectives and causes no significant harm to the other environmental objectives. In addition, operations must meet minimum safeguards.

Reporting principles

The IFRS-compliant accounting principles followed for the consolidated financial statements are also applied to calculate the key figure for Metsä Board’s turnover. The overall turnover used to calculate the key figure corresponds to the turnover disclosed in the consolidated financial state- ments. The accounting principles used for turnover are discussed in Note 2.2 to the consolidated financial statements.

Capital expenditure includes additions to tangible and intangible fixed assets, including any additions to right-of-use assets recognised based on long-term lease agreements. Any increase in goodwill recognised for acqui- sitions is not included in the capital expenditure specified in the Taxonomy. These items are handled in accordance with IAS 38 Intangible Assets, IAS 16 Property, Plant and Equipment, and IFRS 16 Leases. Additions to intangible assets are presented in Note 4.1, and additions to property, plant and equipment in Note 4.2, to the consolidated financial statements.

The numerator for turnover and capital expenditure encompasses the items related to the assets or processes of Taxonomy activities. To avoid double counting, external turnover has been included in the Taxonomy operations only once. In addition, measures have been adopted to ensure that capital expenditure and operating expenses are kept separate for each operation.

Total operating expenses include research and development costs rec- ognised as expenses, and the maintenance costs of production units and property, supplemented by the costs of waste management and short-term lease agreements. The reported expenses include both external service costs and the wages, including indirect employee costs, of the company’s own employees responsible for the listed activities. In the group’s income statement, the operating expenditure specified in the Taxonomy is included in materials and services, employee expenses and other operating expenses. Operating expenses are disclosed in Note 2.4 to the consolidated financial statements.

Changes compared with the previous year

The materiality of activities was reassessed in 2025 based on the materiality principle introduced by the new Delegated Regulation. Activities accounting for less than 10% of total turnover and capital expenditure were excluded from the Taxonomy reporting. No eligible turnover or capital expenditure was identified based on the materiality assessment. Activities in the following sectors were excluded from the assessment: construction and real estate activities and energy

Metsä Board has assessed its operating expenditures as immaterial for 2025, as the total operating expenditures falling under the scope of the Taxonomy do not reflect the company’s core activities and do not cover a significant share of its overall operating expenditures. Total operating expenses for 2025 amounted to EUR 151 million.

40

Report of the Board of Directors | Metsä Board Annual review 2025

Proportion of turnover and CapEx from products or services associated with Taxonomy-eligible or Taxonomy-aligned economic activities - disclosure covering year 2025 (summary KPIs)

Financial year 2025

Breakdown by environmental objectives of Taxonomy aligned activities

KPI

Total

Proportion of Taxonomy eligible activities

Taxonomy aligned activities

Proportion of Taxonomy aligned activities

Climate Change Mitigation

Climate Change Adaptation

Water

Circular Economy

Pollution

Biodiversity

Proportion of enabling activities

Proportion of transitional activities

Not assessed activities considered non-material

Taxonomy aligned activities in previous financial year (2024)

Proportion of Taxonomy aligned activities in previous financial year (2024)

EUR m

%

EUR m

%

EUR m

%

Turnover

1,775.7

0%

0,0

0%

2,7

0%

CapEx

139.5

0%

0,0

0%

11,4

7%

41

E1 – Climate change

Material impacts, risks and opportunities related to climate change mitigation and energy

Impacts

Value chain stage

Time horizon

Risks and opportunities for Metsä Board

Value chain stage

Time horizon

Analysis from the perspective of IPCC’s 1.5 °C and 4.3 °C scenarios*

Greenhouse gas emissions in own operations

Metsä Board has a nationally significant role as a producer of renewable energy. Bio-based fuels from wood-based production side streams and logging residue.

Market opportunity: Metsä Board's produc- tion and use of renewable energy can replace fossil sources; 75% (75) of the energy used in production (Scopes 1 and 2) is already renewable.

High share of renewable energy and resource efficiency enabling competitive carbon footprint for products and greater competitive advantage in the 1.5 °C scenario compared with the 4.3 °C scenario

Greater long-term opportunity to create a BECCU (Bio-Energy with Carbon Capture and Utilisation) business and increase fossil-replacing bio-based products in the market in the 1.5 °C scenario compared with the 4.3 °C scenario

Climate neutrality of biogenic carbon dioxide as a key driver of investment in the BECCU value chain, potential negative effects of the Taxonomy change on companies' willingness to invest, and increased difficulty in achiev- ing the 1.5 °C scenario

Smaller regulatory impacts, as well as risks and opportunities, in the 4.3 °C scenario

Classification of the company's wood-based carbon dioxide emissions as climate neutral

Regulatory opportunity: Recognition in EU regulations of wood-based carbon dioxide capture and utilisation as a key technology to mitigate climate change. Creating market drivers and investment incentives

Climate-warming green- house gas emissions from Metsä Board's production (Scopes 1 and 2)

Regulatory risk: Regulatory requirements for emission reductions, use of forest industry side streams as energy, and wood-based carbon dioxide emissions. Changes in energy and greenhouse gas emissions pricing, which may increase production and transport costs

Greenhouse gas emissions in the upstream and downstream value chain

The climate-warming impact of Metsä Board’s upstream and downstream value chain (Scope 3)

Market opportunity: Metsä Board’s main raw material, wood, which is mainly procured from Finnish and Swedish forests, keeps transport distances moderate.

Greater regulatory and market risks and opportunities in the 1.5 °C scenario than in the 4.3 °C scenario

The value chain’s motivation to produce and share information about emissions is lower in the 4.3 °C scenario, which makes it more difficult to measure Scope 3 emissions and commit the value chain to emissions reduc- tions than in the 1.5 °C scenario

Regulatory and market risk: Regulatory and customer requirements related to reducing greenhouse gas emissions in the value chain. Challenges in identifying, measuring and reduc- ing the climate impacts of the value chain

Carbon balance of forests

Provision of Metsä Group’s forest management services for regenerative forestry to the parent company's own- er-members, promotion of carbon storage in commer- cial forests, development of the verification of the carbon balance impacts of wood supply and forest manage- ment, and the procurement of wood mainly from the forests of owner-members, who own 32% of Finland's forests

Market opportunity: Increased awareness of regenerative forestry. Increased trust in Metsä Board among customers, consumers and stakeholders. The importance of wood as the basis for the bioeconomy, circular economy and innovations based on renewable raw materials

Greater regulatory and market risks and opportunities in the 1.5 °C scenario than in the 4.3 °C scenario

In the 4.3 °C scenario, the information about forests’ carbon balance and products’ biogenic carbon storage is underutilised, weakening opportunities to optimise the climate benefits and market opportunities of wood-based value chains

Market and regulatory opportunity and risk: The development of voluntary carbon markets and EU regulation concerning the certification of carbon removals provide opportunities for improving forests’ carbon storage and tree growth through active forest management. Risk of reduced availability of wood raw material resulting from market growth

Regulatory risk: Regulation of forest use as carbon sinks and reservoirs, and the resulting restrictions on harvesting volumes. Frag- mentation of legislation and failure to take local conditions and ecosystem services into account, which may lead to sub-optimisation of forest management from the perspective of ecosystem services.

Market risk: Consumers’ increasing criticism of forest use because they associate wood con- sumption with the decrease in the carbon sinks and reservoirs in forests. The size of this risk will be influenced by Metsä Group’s success in its regenerative forestry targets and in main- streaming regenerative forestry measures

42

Report of the Board of Directors | Metsä Board Annual review 2025

Impacts

Value chain stage

Time horizon

Risks and opportunities for Metsä Board

Value chain stage

Time horizon

Analysis from the perspective of IPCC’s 1.5 °C and 4.3 °C scenarios*

Products

Metsä Board’s use of fossil-free raw materials and packaging materials

Regulatory opportunity: Regulations that recognise the potential of forest industry products to replace materials made from fossil raw materials or materials that cause high emissions

Greater regulatory and market risks and opportunities in the 1.5 °C scenario than in the 4.3 °C scenario

In the 4.3 °C scenario, products’ carbon footprints and the biogenic carbon stored in products do not guide customer choices, making it more difficult to bring new bio- based products to market than in the 1.5 °C scenario

Metsä Board's production of wood-based carbon-storing and recyclable fibre and other products that keep biogenic carbon in use

Market opportunity: Metsä Board’s long-term efforts to promote resource efficiency and fossil-free operations supports its customers' climate goals; climate benefits are verified through life cycle assessments. Consumers favour easily recyclable or reusable products made from a renewable fossil-free raw material. Wood-based carbon dioxide and its capture support the sustainable use of raw materials and the development of the hydrogen economy

Regulatory risk: Regulation that does not identify the climate benefits of products based on renewable wood raw material but primarily focuses on promoting recycled raw material

Physical risks related to climate change adaptation

Risks for Metsä Board

Value chain stage

Time horizon

Analysis from the perspective of IPCC’s 1.5 °C and 4.3 °C scenarios*

Acute hazards

An analysis of the physical risks of production units conducted in 2024 indicated that the physical risks at Metsä Board’s production units were clearly below average, which supports the company’s competitiveness in a changing climate

Risks have considerably higher impacts in the 4.3 °C scenario than in the 1.5 °C scenario.

Disruptions in production caused by storms, droughts and floods, and problems with the transport of raw materials and products

Chronic hazards

Metsä Board’s mills are not located in or do not withdraw water from areas at high water risk, which supports the company’s competitiveness in the face of climate change

Risks have considerably higher impacts in the 4.3 °C scenario than in the 1.5 °C scenario.

The increased frequency of droughts weakens the availability of the process and cooling water needed by mills, and causes production breaks

Harvesting conditions weaken due to a lack of snow and frost and because of increased precipitation.

Climate change results in temperatures rising at different rates in various parts of the world. In the 4.3 °C scenario, the long-term (2050) temperature rise in Finland is estimated to be 6–7 °C, making the impacts of the risks more likely and greater than in the short term

A significant rise in temperature during the life cycle of Finnish forests will increase emissions from peatland forests, cause changes in the prevalence of tree species and increase problems caused by invasive species in forests

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

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

Upstream value chain

Own operations

Downstream value chain

Short-term (less than one year)

Medium-term (1–5 years)

Long-term (more than 5 years)

* The 1.5 °C scenario corresponds to RCP 1.9, in which global warming resulting from climate change remains at or below 1.5 °C. The 4.3 °C scenario corresponds to RCP 8.2050, in which global warming resulting from climate change averages 4–5 °C (by 2050).

43

Metsä Board’s 2030 sustainability targets

2030 target

2025

2024

2023

2018

Improvement in energy efficiency from the 2018 level, %

+10%

-7.2

+0.9

-5.8

2.4 MWh/t

Fossil-based carbon dioxide emissions (Scope 1 + Scope 2 market-based), t

0 t

121,252

251,708

183,600

577,875

Greenhouse gas emissions from logistics purchased by Metsä Board from the 2022 level (Scope 3, category 4), %/tkm

-30%

-5.8

-

Metsä Group's 2030 sustainability targets

MG: Amount of forest regeneration and young stand management from the 2018 level, %

+30%

+14

+18

+14

33,265 ha

MG: Amount of forest fertilization from the 2018 level, %

+50%

+126

-22

-26

9,115 ha

MG: Share of continuous cover forestry in peatland forest regeneration, %

30%

18

15

17

-

The production line for unbleached pulp in Kemi, which became the property of Metsä Board in 2024, has not yet been included in the calculations concerning water and energy efficiency targets.

The actual figure for Scope 3 for the base year 2022 is 381,836 tCO 2 e. In 2025, the absolute reduction in emissions was 121,256 tCO 2 e. The target applies from 2025 onwards, so historical figures are not reported.

MG: The target has been set at the level of Metsä Group.

Metsä Board’s 2030 sustainability targets, and their setting and moni- toring, are discussed in greater detail under Sustainability governance and strategy and Material sustainability-related impacts, risks and opportunities .

The company’s targets for reducing greenhouse gas emissions (Scopes 1 and 2) have been approved by the Science Based Targets initiative (SBTi), and they meet the strictest requirements of the Paris Agreement, aimed at limiting global warming to 1.5 °C.

Regarding the value chain (Scope 3), the target year for the SBTi- approved target was 2024, and Metsä Board is assessing and updating its target. In addition, a target was set in 2025 to reduce greenhouse gas emissions from transport purchased by the company.

Progress in targets

Fossil-based carbon dioxide emissions (Scopes 1 and 2 mar- ket-based) – The production curtailments caused by the market situation and investment shutdowns reduced fossil-based carbon dioxide emissions in 2025. Completed investments and energy efficiency measures also reduced emissions. The increase in the share of guarantees of origin in electricity procurement reduced fossil carbon dioxide emissions from purchased energy. Overall, fossil-based carbon dioxide emissions (Scopes 1 and 2, market-based) have decreased by 79% from 2018 to 2025.

Improvement in energy efficiency from the 2018 level − In 2025, shutdowns at mills due to the market situation and investments weak- ened energy efficiency despite the development measures taken.

Resilience

Metsä Board’s identification of climate risks and scenario analysis are described in the Material sustainability topics section.

In 2024, the ability of Metsä Board’s strategy to respond to climate change was examined in a climate resilience analysis carried out in con- nection with Metsä Group’s resilience analysis. Metsä Group’s Executive Management Team participated in the climate resilience analysis. Metsä Board’s CEO is a member of Metsä Group’s Executive Management Team. The analysis was used in the preparation of the climate transition plan.

The resilience analysis covered Metsä Board and Metsä Group’s own operations and their value chain. The strategy’s resilience was assessed by comparing its adaptive change capability and transformative capability with the material climate risks identified in the risk assessment. Adaptive change capability means the gradual adaptation and mitigation actions

mainly in the company’s own operations. Transformative capability means actions promoting change that have a broader impact in value chains and communities, for example. The analysis indicated that investing in adaptive change capability and transformative capability strengthened Metsä Board’s climate resilience. The significance of transition risks and opportunities is highlighted, particularly in the scenario mirroring the Paris Agreement objectives. In turn, the high-emissions scenario emphasises physical risks. The analysis of material physical and transition risks is updated annually. The climate risk scenario analysis and its results are described on page 43 . The materiality assessment is discussed on pages 31–34 . Metsä Board’s risk management process and its responsibilities are described in greater detail in the Corporate Governance Statement.

The weak predictability of EU legislation is a key uncertainty factor related to the resilience analysis. Adding to uncertainty is the fact that many important details are laid down in provisions separate from the text of directives and regulations. Another significant uncertainty factor is the assessment of the ability of complex natural ecosystems such as forests to adapt to climate change.

Transition plan for climate change mitigation and adaptation

Link to business strategy

At Metsä Board, climate change mitigation and adaptation and regener- ative forestry as part of sustainability work have been integrated into the company’s business and strategic targets. Many Metsä Board sharehold- ers appreciate long-term climate work and continuous development. This is also important to the owner-members of Metsäliitto Cooperative, Metsä Board’s largest shareholder.

Metsä Group’s Stakeholder Engagement unit, steered by Metsä Group’s Sustainability Process Management Team, is responsible for drawing up and updating the climate transition plan for Metsä Group as a whole. The team consists of the directors in charge of sustainability for Metsä Group’s business areas and head office functions. In 2025, Metsä Board was represented by the SVP, Development. Metsä Board is responsible for the action plan covering its own operations, including action and investment plans. Metsä Board’s Corporate Leadership Team approved the extensive climate transition plan in 2024. The company’s Board of Directors was also informed about the plan. Metsä Board’s Corporate Leadership Team and Board of Directors discuss plans related to climate transition and approve

44

Report of the Board of Directors | Metsä Board Annual review 2025

them in accordance with the company’s decision-making practices. Metsä Board’s Board of Directors is the company’s highest body overseeing sustainability. Metsä Board’s CEO is in charge of the implementation of sustainability actions in accordance with the Board’s instructions. This topic is discussed in more detail in the Sustainability governance and strategy section.

Climate targets

Metsä Board’s climate targets and their compatibility with the Paris Agree- ment’s 1.5 °C pathway are described in Metsä Board’s 2030 sustainability targets .

Metsä Group has not yet set post-2030 emissions reduction targets, but planning of the 2050 1.5 °C net zero pathway in accordance with the Paris Agreement is underway, particularly regarding Scope 3 emissions. Concerning fossil-based Scope 1 and Scope 2 carbon dioxide emissions, the target is zero in 2030. No internationally recognised sector-specific decarbonisation development path is currently available for Metsä Group’s industry, the forest industry. Key standards for calculating greenhouse gas emission reductions and setting targets, such as the SBTi guidelines and the GHG Protocol’s guidance on land use in the forestry sector, are also being updated.

Thus far, Metsä Board has not used carbon units purchased outside the value chain to offset or balance emissions. Metsä Board follows the development of voluntary carbon markets, including the EU’s regulation on carbon removal certification (CRCF). They will play a role in balancing Scope 3 residual emissions when working towards the 2050 net zero target.

Strengthening the state of forest nature plays an important role in climate change adaptation. Biodiversity-related sustainability targets and actions are presented in greater detail under E4 – Biodiversity and ecosystems .

Key actions and progress made

Investments and R&D&I activities play a key role in the climate transition. The accompanying diagrams show the key actions planned to implement the climate transition and achieve the targets.

The progress made in the climate transition plan’s implementation is described under Progress in targets and Actions .

To inspire the personnel to commit to sustainability actions, the annual targets for all personnel include at least one target related to sustainability, which is used as the basis for annual bonuses. All Metsä Board employees complete an e-learning course on the basics of sustainability. Climate themes are a central element of the course. An important part of the strat- egy’s implementation is the development of core competence important to the company. Metsä Group’s Academy concept has been developed for this purpose. In 2025, the concept encompassed Academies for sustainability, sales, procurement, leadership and finance. Climate-related topics are of key importance in the Sustainability Academy, and they are also discussed in other academies and leadership programmes.

The reductions in fixed costs achieved through the cost savings and profitability improvement programme launched in 2025 may affect the timing or scope of investments related to the environment and climate. Metsä Board has decided to suspend significant investment projects in the pre-engineering phase which do not offer adequate profitability in the current market situation.

Metsä Board’s 2030 target covers fossil carbon dioxide emissions, which accounted for approximately 95% of the company’s total Scope 1 and Scope 2 greenhouse gas emissions in the base year 2018. The emission reductions described are indicative. The category “Other” includes the closure of the Tako paperboard mill and the impact of energy efficiency measures. The calculation of the reduction level under the Paris Agreement is based on the reduction level estimated by the IPCC (global fossil carbon dioxide emissions will decrease by 48% between 2019 and 2030) and by extending the linear reduction to the years 2018–2030, the emission reduction is about 52%. In addition, Metsä Board’s Scope 3 target is to reduce greenhouse gas emissions from its purchased transport by 30% per tonne-kilometre from 2022 levels by 2030. Metsä Board will assess and update its target.

Financing and costs

Investments are financed with equity and external financing. Metsä Board, as part of Metsä Group, maintains adequate liquidity reserves in accord- ance with Metsä Group’s Treasury Policy. Liquidity risk is managed by using various capital and financial markets to reduce dependence on a single source of financing and to optimise the cost of capital. The optimisation of loan maturity structure is also highlighted in financing decisions. This matter is discussed in more detail in the notes to the consolidated financial statements, section 5.6 Financial management. Any external financing for investments related to the transition plan is obtained in connection with the preparation of the investment decision.

The company aims to use green financing sources in the transition to use fossil-free energy in its production and in other financing plans for industrial operations. Metsä Board uses Metsä Group’s Green Finance Framework to support the financing and refinancing of environmentally sustainable investments. The implementation of the finance framework is monitored by the Sustainable Funding Committee (SFC), which consists of members from Metsä Group’s management, treasury, sustainability and investment management, and is chaired by Metsä Group’s CFO.

In 2025, Metsä Board issued a EUR 200 million green unsecured bond maturing in 2031. The net proceeds from the bond were allocated to refinancing the renewal investment at the Husum pulp mill. The investment is in line with Metsä Group’s Green Finance Framework and supports the achievement of the UN Sustainable Development Goals (SDGs) in the following areas: renewable or fossil-free energy; waste and side stream management; and emissions reduction. In addition, the company signed a EUR 250 million revolving credit facility with a margin tied to long-term climate and energy efficiency targets. The facility replaced the EUR 200 million revolving credit facility expiring in January 2027, which has not been drawn down. The new credit facility matures in 2030 and includes two one- year extension options, subject to the lenders’ consent. The credit facility is intended for the company’s general financing needs.

In recent years, the key investments for phasing out the use of fossil energy have been the renewal investment at the Husum pulp mill, which included the renewal of the recovery boiler and the turbine; the renewal of the turbine at the Kyro board mill; and the renewal of the folding boxboard machine in Simpele. The total value of these investments is approximately EUR 480 million. This item is not broken down in the financial statements. Phasing out the use of fossil energy requires investments in electrifying boilers and processes that currently use fossil fuels at mills, or switching from fossil fuels to fossil-free alternatives.

45

The Taxonomy’s criteria do not currently cover Metsä Board’s core business. The proportion of Taxonomy-eligible business activities is therefore small. Based on the materiality principle in accordance with the new Delegated Act, activities related to Metsä Board’s turnover, capital, and operating expenses have been excluded from the assessment. Metsä Board had no investments in coal, oil or gas.

Other considerations

After abandoning fossil fuels, only biogenic greenhouse gases are left, most of which is biogenic carbon dioxide, classified as climate neutral in

the EU criteria. In addition, wood-based energy generates small amounts of biogenic methane and nitrous oxide, which, according to the ESRS definition, are included in total Scope 1 and Scope 2 GHG emissions, along with fossil-based carbon dioxide emissions.

Key assets, greenhouse gas emissions lock-in, and related risks are described in the Financial effects section.

Metsä Board has not been excluded from the EU Paris-aligned benchmarks.

More information about the climate transition plan can be found on Metsä Board’s website .

Areas of action related to climate change mitigation and adaptation

Reducing greenhouse gas emissions

Increasing the substitution benefit of products

Further improving efficiency in the use of

energy, water and materials

Renewable wood fibre from

certified forest origins

Strengthening fibre recycling loops

Metsä Group: Investigation of technical capture of biogenic carbon dioxide

Metsä Group: Promotion of carbon sequestration and biodiversity in forests

Good governance

Risk management

Strengthening personnel capabilities

Cooperation and advocacy

Plan to phase out the use of fossil energy in production by 2030 (Scope 1 & 2, market-based)

Fossil-based CO 2 emissions (tCO 2 )

577,875

-43%

-24%

-0.4%

-11%

121,252

-8.4%

-4.2%

-8.4%

Fossil-based CO 2 emissions in the base year (2018)

Process fuels: switching to renewable fuels or electrification

Purchased energy: switching to fossil-free heat and electricity

Other

Power plants: switching to renewable fuels

Emissions in the reporting year (2025)

Other

2030 target

0

With a 79% reduction in fossil-based Scope 1 and 2 CO 2 emissions from 2018 to 2025, Metsä Board is already below the 1.5°C Paris-aligned 2030 emissions reduction level

The reduction level aligned with the Paris Agreement 1.5°C pathway

700,000

600,000

500,000

400,000

300,000

200,000

100,000

0

Metsä Board’s 2030 target covers fossil carbon dioxide emissions, which accounted for approximately 95% of the company’s total Scope 1 and Scope 2 greenhouse gas emissions in the base year 2018. The emission reductions described are indicative. The category “Other” includes the closure of the Tako paperboard mill and the impact of energy efficiency measures. The calculation of the reduction level under the Paris Agreement is based on the reduction level estimated by the IPCC (global fossil carbon dioxide emissions will decrease by 48% between 2019 and 2030) and by extending the linear reduction to the years 2018–2030, the emission reduction is about 52%. In addition, Metsä Board’s Scope 3 target is to reduce greenhouse gas emissions from its purchased transport by 30% per tonne-kilometre by 2030, relative to a 2022 baseline. Metsä Board will assess and update its target.

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Report of the Board of Directors | Metsä Board Annual review 2025

Policies

Metsä Board’s climate change work is guided by Metsä Group’s Environ- mental Policy. Metsä Board is committed to transitioning to fossil-free fuels at its production units, replacing purchased electricity and heat with fossil-free alternatives, and improving its energy efficiency. Policy commitments and related actions are the key measures for managing the identified impacts, transition risks and opportunities. Commitments also encompass ways to manage physical climate risks through water efficiency and sustainable forestry, for example.

Environmental management and environmental performance are guided by the requirements of the production units’ certified quality, environmen- tal and energy efficiency systems. The production units systematically conduct internal and external audits in accordance with the ISO 14001 and ISO 50001 standards.

In the Leader in sustainability strategic programme, the climate focus is on reaching the strategic sustainability targets for reducing fossil-based carbon dioxide emissions, and water and energy efficiency.

Forest use is guided by Metsä Group’s principles for forest use and management, in which Metsä Group commits to increasing the amount of carbon bound in forests and to promoting forest biodiversity, among other things. Certified quality and environmental management systems are in use in Metsä Group’s wood supply.

Suppliers are required to commit to Metsä Group’s Supplier Code of Conduct or to their own equivalent codes. Among other things, the Supplier Code of Conduct encourages the setting of reduction targets for greenhouse gas emissions in accordance with the principles of the Science Based Targets initiative, and the continuous improvement of environmental performance and efficient energy use. Suppliers are required to adopt a certified environmental management system where applicable. The Code of Conduct and policies are discussed in more detail under G1 – Business conduct .

Actions

Greenhouse gas emissions and energy in the company’s own operations

Continuous actions

To achieve its emissions reduction target, Metsä Board plans investments and measures to replace fossil fuels used by the company with renewable fuels or fossil-free electricity. The investments and actions apply to the fuels and backup fuels used at power plants and to the process fuels used at production units. The company will also transition to fully renewable or fossil-free alternatives in energy purchased for its production operations. In addition, the company will improve the efficiency of its energy, material and water use through continuous development and investment. These investments and measures are planned with a high level of automation and the best available technology in mind. The utilisation rate and production speed of mills have a significant impact on the efficiency of energy and water use. Reducing water use is a way of mitigating climate change, as process water use and wastewater treatment consume energy, causing greenhouse gas emissions. Measures related to water use are discussed under E3 – Water and marine resources .

Actions taken during the reporting year

Scope 1 emissions

Metsä Board completed a EUR 60 million renewal project at its Simpele board mill. The renewed paperboard production line started up in October 2025. The investment improves both the quality of folding boxboard and production efficiency. In addition, a fossil fuel, liquefied petroleum gas, was replaced with electricity. The completion of the investment and the replacement of peat with renewable fuels at the Simpele power plant in 2024 increased the share of fossil-free energy of the energy used by the plant to 98%.

The closure of the Tako paperboard mill in the summer of 2025 significantly reduced Metsä Board’s fossil carbon dioxide emissions, as the mill’s main fuel was natural gas. Before the mill was closed, emissions were reduced by the partial replacement of natural gas with biogas at the Tako power plant.

Optimising the minimum load of the Husum pulp mill’s recovery boiler reduces the amount of fossil heavy fuel oil used as backup fuel when the pulp mill is not operating at full capacity.

The measures under the Kemi paperboard mill’s development programme to improve water and energy efficiency were completed in 2025. To achieve its 2030 target, Metsä Board has mill-specific plans for investments to improve energy efficiency. The investment decisions will be made over the coming years. Investment decisions and roadmap progress are reviewed as part of annual planning. Future investments that are sig- nificant for climate change are reported in more detail in the Sustainability statement once they have been approved.

Scope 2 emissions

Metsä Board obtained guarantees of origin for all the electricity it pur- chased, which significantly reduced its Scope 2 emissions for 2025.

Other actions

In 2025, Metsä Group continued its investigations into carbon dioxide capture and piloted carbon dioxide capture at the Rauma pulp mill of Metsä Fibre, an associated company of Metsä Board. Metsä Group is moving for- ward with its carbon dioxide capture project in stages. Profitable business requires large investments and the development of recovery technology and the market.

47

Greenhouse gas emissions in the value chain

Continuous actions

The value chain’s greenhouse gas emissions are reduced through emis- sions reduction targets jointly set by Metsä Group and its suppliers. For example, the joint 2030 target of Metsä Group and VR, a logistics group, will halve emissions from the transports covered by the cooperation. The joint target with Royal Wagenborg, a Dutch maritime logistics company, is to reduce products’ carbon dioxide emissions from marine transports by 30% (per tonne per mile) from the 2021 level by 2030.

Logistics emissions will be continuously reduced by planning efficient routes, minimising transport distances, optimising fill rates and favouring rail connections to road connections on selected routes. For example, in the transport of products from the Kemi paperboard mill to ports, the load size of transport units is maximised, and all fuels are fossil-free. The measures primarily impact affect local communities and the company’s own workforce.

Actions taken during the reporting year

In accordance with Metsä Group’s Scope 3 target set in 2024, the prepa- ration of emissions reduction plans began in 2025. In 2025, no significant capital or operating costs were associated with greenhouse gas reductions in the value chain.

Carbon balance of forests

Continuous actions

Metsä Group’s principles of regenerative forestry aim for measures in wood supply and forest services with which the state of nature will begin to verifiably improve in Finland. Regenerative forestry actions will increase forests’ carbon storage, biodiversity and ability to adapt to climate change. The calculation and reporting of the carbon balance of forests is being developed in cooperation with forest owners and partners. Forest certifica- tion demonstrates that the forest has been managed sustainably.

Key practical actions related to climate change mitigation include the following:

Forests are swiftly renewed after regeneration felling. The faster and better a new forest is established, the sooner it begins to store carbon from the atmosphere. Cultured seeds and seedlings of local tree species are used in renewal whenever available. Domesticated trees grow better than naturally generated trees.

Young stand management and thinning ensure that stands remain vital, and growth is focused on the best trees.

Forest fertilisation improves tree growth, maintains the growth condi- tions of the soil and ensures the vitality of trees.

Increasing the share of continuous cover forestry helps curb and adapt to climate change, as it minimises the GHG emissions from peatland forests. The goal of continuous cover forestry is to maintain a steady sur- face level of groundwater to prevent the carbon stored in peat from being released into the atmosphere and to minimise impacts on waterbodies.

Metsä Group’s Wood Supply and Forest Services have strategic sustaina- bility targets for these actions, and they are presented in the table on page 4 4 . The actions particularly affect Metsä Group’s owner-members.

Products

Continuous actions

The aspects most relevant in terms of the climate impact and carbon footprint of paperboard packaging are the use of renewable raw material, the energy used in production, and the light weight and recyclability of the paperboard itself. Further reducing the weight of paperboard is a priority in Metsä Board’s R&D operations. As Metsä Board shifts to using fully fossil-free energy in its production, the carbon footprint of the company’s products will continue to decrease. Metsä Board’s paperboards also offer an alternative to packaging materials made of non-renewable raw materials such as plastic.

According to case-specific life cycle assessments carried out by Metsä Board, the carbon footprint of healthcare packaging, perfume and tea packaging made from the company’s fresh fibre paperboard can be more than 40−60% smaller than that of recycled fibre or solid bleached board packaging of equivalent stiffness representative of packaging used in Europe. The results of the assessments have been verified by the Swedish research institute IVL Svenska Miljöinstitutet.

Metsä Board’s case studies comprising life cycle assessments of berry and takeaway food packaging show that packaging made from Metsä Board’s paperboard has a significantly smaller carbon footprint than plastic (PET, R-PET, PP) packaging, regardless of the product’s end-of-life treatment. In a simplified scenario where all packaging was incinerated at the end of its life cycle, the carbon footprint of packaging made from Metsä Board’s paperboard was 87–91% lower than that of plastic packaging. This scenario did not take the significantly higher recycling rates for cardboard, which further increase its climate benefits, into account. The study took both biogenic carbon storage and biogenic carbon emissions into account. The results of the assessments have been verified by an independent panel consisting of representatives from the Swedish research institute RISE and SimaPro UK.

The technical background reports and verification statements for the car- bon footprint assessments are available on Metsä Board’s website. Carbon footprint calculations are constantly being developed and updated.

Actions taken during the reporting year

In 2025, Metsä Board reduced the use of fossil-based binders in paper- board at its Husum paperboard mill. The investment programme launched at the Simpele paperboard mill in 2024 will enable the use of bio-based binders for paperboard coating in the future. R&D work will continue for other production units. These actions primarily affect customers and consumers.

Development work on protective wrapping for products continued in 2025. Thinner wrapping films were tested in mill trials and introduced in production at some mills, reducing the use of fossil-based plastic. A separate development project specified the cost and technical impacts of fossil-free raw material alternatives.

As of 2025, the target related to fossil free raw materials and packaging materials is no longer be monitored as part of the overall target framework. Almost all (99%) Metsä Group’s raw materials and product packaging materials, including wood-based raw materials, are fossil-free. In the coming years, the main goal is to reduce the carbon footprint of products.

48

Report of the Board of Directors | Metsä Board Annual review 2025

Further information about the company’s R&D operations is available under section E5 – Resource use and circular economy and in the Board of Directors’ report under R&D and innovation .

Climate change adaptation

Continuous actions

Climate change adaptation calls for adaptation to both acute hazards such as extreme weather phenomena and chronic hazards, caused by the impacts of climate change on water availability, harvesting conditions, growth conditions of different tree species, or snow, storm, drought, forest fire, insect, and fungi damage in forests.

Metsä Board continuously prepares for the threats arising from extreme weather phenomena at both the company and mill levels. Examples of actions include controlling water levels with dam arrangements and ensuring power distribution in exceptional situations. The supply chain is preparing for alternative transport routes or partners. The company’s production units are not located in areas of high water risk, which supports the company’s competitiveness in the face of climate change. Metsä Board’s target of reducing process water use and increasing water recycling within the process also reduces the water risk. These actions particularly affect local communities.

Metsä Group’s wood supply always considers weather conditions and related changes in harvesting. Wood is harvested only in suitable con- ditions. If required, wood storage can be used to smooth out variation caused by harvesting conditions. Metsä Group’s regenerative forestry principles and sustainable forest management services help forests adapt to climate change and promote forest biodiversity. Regenerative forestry is discussed in greater detail under E4 – Biodiversity and ecosystems .

In 2025, no significant costs were related to climate change adaptation measures, and no such costs are expected in the coming years.

Financial effects

No material physical climate risks are associated with Metsä Board’s production units. The identification and assessment of physical climate risks at production units and the climate scenarios used are discussed in the Material sustainability-related impacts, risks and opportunities section.

No such assets at Metsä Board’s production units have been identified that could be subject to a material transition risk or might lose value due to regulation related to the green transition (stranded assets). Metsä Board’s production still generates fossil-based carbon dioxide emissions, but the company aims to phase out the use of fossil energy in the production by 2030. After this, production will no longer be connected with fossil-based carbon dioxide emissions. However, a small amount of biogenic green- house gases that are included in the Scope 1 and Scope 2 framework will still be generated.

Metsä Board is not significantly involved in sectors posing a substantial transition risk, such as the coal, gas or oil industries. Metsä Board’s main transition risks are related to regulation concerning forest use and wood- based energy, the potential impact of which could increase costs in the long term.

Metsä Board is in the scope of the EU Emissions Trading System (ETS). In internal carbon pricing, the EU emissions trading price forecast for a tonne of carbon dioxide is used in the income and expense entries for production units. The price of emission allowances is expected to rise in line with the purpose of the emissions trading system. All investment and energy efficiency calculations also take the price of carbon dioxide into account, thereby steering processes towards low-carbon solutions. No estimate has been made of the share of emissions to which shadow pricing is applied. The price is determined annually, and for investments in a spe- cific year, the price for that year is used. The price remains the same across the investment period. The company does not disclose the carbon price or related assumptions, as it considers this to be critical and strategically sensitive information for its business.

In 2025, a total of 363,421 (385,197) tonnes of free emission allowances under the EU ETS was allocated to Metsä Board’s mills. The amount does not include allocation for Kaskinen, which was unavailable at the time of reporting. Known or reasonably expected cost increases include the end of free emission allowances after 2025 for mills at which sustainable biomass incineration accounted for, on average, more than 95% of the mill’s GHG emissions in 2019−2023. The EU Emissions Trading System is being updated, and based on current knowledge, free emission allowances will be phased out entirely after 2030. Emission allowances are discussed in more detail in the consolidated financial statements under Intangible assets .

Regarding the financial opportunities of low-carbon products, Metsä Board’s existing fresh-fibre paperboard packaging is particularly suited to replace fossil-based alternatives. Potential future products will be targeted at the global packaging market. Major carbon capture opportunities can be found in pulp mills, as the carbon dioxide generated there can be used in the chemical industry and hydrogen economy.

49

Metrics

Energy consumption

MWh

2025

2024

FUELS

Oil

138,884

240,897

Gas

324,280

434,125

Coal

0

Waste

24,102

39,482

Peat

0

17,306

Wood

4,554,519

5,441,356

PURCHASED ENERGY

Purchased electricity and heat, renewable wood-based

604,523

595,710

Purchased electricity and heat, other renewable

69,703

67,832

Purchased electricity and heat, fossil

8,865

138,860

Purchased electricity and heat, nuclear

1,241,024

1,214,985

CONSUMPTION OF SELF-GENERATED NON-FUEL RENEWABLE ENERGY

Consumption of self-generated hydro power

19,641

30,010

TOTAL ENERGY CONSUMPTION

Total energy consumption, renewable wood-based

5,159042

6,037,066

Total energy consumption, other renewable

89,344

97,842

Total energy consumption, fossil

496,130

870,670

Total energy consumption, nuclear

1,241,024

1,214,985

Total energy consumption

6,985,541

8,220,563

ENERGY INTENSITY (MWh/EUR turnover)

Energy intensity

0.004

0.005

The turnover used in energy intensity calculations can be found in the consolidated finan- cial statements under Consolidated statement of comprehensive income .

Energy consumption by energy source

%

2025

2024

Renewable wood-based

74

73

Other renewable energy

1.3

1.2

Nuclear energy

18

15

Fossil fuels

7.1

11

Energy production

MWh

2025

2024

Self-generated energy, renewable

4,135,116

4,840,823

Self-generated energy, fossil

247,232

398,199

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Report of the Board of Directors | Metsä Board Annual review 2025

GHG emissions

Base year 2022

2025

2024

Change % (2025/2024)

Scope 1 GHG emissions

Gross Scope 1 GHG emissions (tCO 2 e)

139,723

192,098

-27%

Percentage of Scope 1 GHG emissions from regulated emission trading schemes (%)

100

0%

Scope 2 GHG emissions

Gross location-based Scope 2 GHG emissions (tCO 2 e)

143,634

259,496

-45%

Gross market-based Scope 2 GHG emissions (tCO 2 e)

2,082

84,990

-98%

Significant Scope 3 GHG emissions

Total Gross indirect (Scope 3) GHG emissions (tCO 2 e)

1,587,316

1,789,138

-11%

1 Purchased goods and services

400,842

485,533

-17%

2 Capital goods

33,049

27,746

+19%

3 Fuel and energy-related activities (not included in Scope 1 or Scope 2)

42,212

73,778

-43%

4 Upstream transportation and distribution

368,052

280,567

300,233

-6.6%

5 Waste generated in operations

661

727

-9.1%

6 Business traveling

607

937

-35%

7 Employee commuting

1,883

1,926

-2.2%

9 Downstream transportation

5,571

7,304

-24%

10 Processing of sold products

348,447

275,061

+27%

11 Use of sold products

1,906

1,846

+3.3%

12 End-of-life treatment of sold products

436,968

563,093

-22%

15 Investments

34,601

50,954

-32%

Total GHG emissions

Total GHG emissions (location-based) (tCO 2 e)

1,870,673

2,240,732

-17%

Total GHG emissions (market-based) (tCO 2 e)

1,729,120

2,066,226

-16%

No base year or target year has been reported for Scopes 1 and 2 emissions, as Metsä Board’s emissions reduction target only applies to fossil carbon dioxide emissions. The current Scope 3 target focuses on reducing greenhouse gas emissions from transport services purchased by the company. The target is intensity-based, and the preparation of related emis- sions reduction plans began in 2025. As emissions modelling is still in its early stages, no target year has been reported as yet. Planning for an absolute Scope 3 emissions reduction target is underway. The targets are discussed in more detail in section E1 Metsä Board’s 2030 sustainability targets and in the transition plan for climate change mitigation .

GHG intensity

2025

2024

GHG intensity based on turnover, Scope 1, 2 and 3 (market-based), tCO 2 e/euros

0.001

GHG intensity based on turnover, Scope 1, 2, 3 (location-based), tCO 2 e/euros

0.001

GHG intensity based on turnover, Scope 1 and 2 (market-based), tCO 2 e/euros

0.0001

0.0002

GHG intensity based on turnover, Scope 1 and 2 (location-based), tCO 2 e/euros

0.0002

GHG intensity based on production, Scope 1 and 2 (market-based), tCO 2 e/t

0.1

GHG intensity based on production, Scope 1 and 2 (location-based), tCO 2 e/t

0.1

0.2

The turnover used in emission intensity calculations can be found in the consolidated financial statements under Consolidated statement of comprehensive income .

Wood-based biogenic carbon dioxide emissions

tCO 2

2025

2024

Wood-based biogenic carbon dioxide emissions

1,803,590

2,154,777

51

Reporting principles for metrics

Forest management targets

The scope of forest regeneration and young stand management includes, in hectares, the soil preparation and young stand man- agement, i.e. early cleaning and thinning, conducted by Metsä Group’s Wood Supply and Forest Services. The scope of forest fertilisation includes, in hectares, the growth, boron and ash fertilisation conducted by Metsä Group’s Wood Supply and Forest Services. The share of continuous cover forestry in peatland forest regeneration includes standing sales concluded by Metsä Group’s Wood Supply and Forest Services, as well as the group selection cutting, selection cutting and strip felling carried out to regenerate peatlands, and it is calculated based on the amount of felling. If land area-based felling was used in the calculation, the result is 27% (22).

Energy consumption

Energy consumption encompasses all Metsä Board’s production units. Metsä Board’s internal heat transfer is taken into account to avoid double counting. Energy consumption is expressed as final energy consumption, which means that the efficiency factors of electricity and heat are not taken into account. Final energy consumption is obtained by summing up the fuel consumed at production units, self-generated hydropower, and the amount of purchased electricity and purchased heat. Internal logistics, including the fuel consumption by internal logistics, and the electricity purchased for buildings outside mill areas such as warehouses and office facilities, is excluded from the calculation, as their share of total energy consumption, and thus of Scope 1 and Scope 2 emissions, is assessed as non-material. Local fac- tors are used to calculate the energy contained in different fuels. Metsä Board’s heat consumption is mainly based on steam. Peat is classified as a fossil fuel. Waste is partly fossil-based and partly bio-based. The classification of waste into fossil and biogenic is done for each mill and is based either on the composition of the waste or on factors provided by Statistics Finland when the origin is not specifically verified. Differences in composition are taken into account in the emissions calculation, and for this reason the shares are not reported separately.

Metsä Board’s main business, paperboard and market pulp busi- ness, is considered a high impact climate sector. Energy intensity has therefore been calculated based on the entire company’s energy consumption and turnover.

The improvement of energy efficiency is determined as specific energy consumption, meaning the ratio of energy consumption and production volume. Specific energy consumption is calcu- lated for individual production lines, including the consumption of electricity, heat and fuels as megawatt hours (MWh). Tonnes and cubic metres are both used as units in production volume calculations. They are considered to be of equal value. The energy efficiency of Metsä Board’s power plants is not taken into account in calculations. Discontinued lines are included in the calculations for as long as they are used in production. Closed down in 2025, Tako was added to the company’s building stock. After the end of production operations, the electricity used has remained fossil-free, and the guarantees of origin covered all purchased electricity used for property maintenance throughout the year. New production units are included in the calculations from the year in which their production begins.

The amount of waste used as fuel has been corrected from 71,382 megawatt-hours to 39,482 megawatt-hours. The amount of self-generated fossil energy has been corrected from 417,213

megawatt-hours to 398,199 megawatt-hours. The corrections were made due to errors identified after the 2024 reporting, including the use of an incorrect energy unit in the plant’s calcula- tion. The corrections have also been reflected in the total energy consumption for 2024.

GHG emissions

GHG emissions include the emissions of all Metsä Board production units. In emissions calculations, Metsä Board’s internal heat transfer is taken into account to avoid double counting. GHG emissions are calculated in accordance with the GHG Protocol Corporate Accounting and Reporting Standard and the Corporate Value Chain (Scope 3) Accounting and Reporting Standard. The scope of reporting is based on operational control. Reporting covers direct GHG emissions (Scope 1) from Metsä Board’s own operations, indirect GHG emissions (Scope 2) from the production of purchased energy, and indirect GHG emissions from other parts of the value chain (Scope 3), including upstream and downstream. Power plant emissions are allocated to the production units that use the energy generated by the plants.

The calculation includes all the greenhouse gases covered by the GHG Protocol (CO 2 , CH 4 , N 2 O, HFCs, PFCs, SF 6 and NF 3 ). Emissions have been converted into carbon dioxide equivalents.

Scope 1 emissions have been calculated from the fuels used by production units. The calculation is based on supplier-specific emission factors for fuels or on national emission factors. Diffuse emissions have been excluded. Two different methods are used for Scope 2 carbon dioxide emissions. The market-based method uses supplier-specific emissions factors, supplemented with national residual mix emission factors for untracked purchased electricity. In the location-based method, country-specific average emission factors for electricity are used. The residual mix factors and country-specific factors have been obtained from the AIB (Association of Issuing Bodies) report on emission factors. The use of emission factors always involves uncertainty, as the factors are based on average values that may not reflect the special characteristics of operations or the situation at the time. Where possible, the factors are updated with supplier-specific values.

In 2025, 100% (90) of Metsä Board’s purchased electricity was covered by guarantees of origin, of which 78% (80) had been defined in electricity purchase agreements. Of all the guarantees of origin for purchased electricity:

72% (75) were nuclear power certificates with a long-term power purchase agreement;

5.3% (5.1) were hydropower certificates with a long-term power purchase agreement;

22% (20) were nuclear power certificates without a long-term power purchase agreement.

In 2025, 35% (37) of Metsä Board’s heat purchases were covered by guarantees of origin defined in heat purchase agreements. Of the guarantees of origin, 100% (100) were biomass certificates from Metsä Fibre’s Äänekoski bioproduct mill, which is Metsä Board’s only heat supplier in Äänekoski. The remaining 65% (61) of purchased heat was acquired from Metsä Fibre at the Kemi and Joutseno integrated mills. Of this, 99.8% (99) was biomass-based renewable heat.

Metsä Board’s 2030 sustainability target, “0 tonnes of fossil-based carbon dioxide emissions”, concerns Scope 1 and Scope 2 emissions, and only encompasses fossil-based carbon dioxide emissions, excluding other greenhouse gases. In other

52

Report of the Board of Directors | Metsä Board Annual review 2025

respects, the target has been calculated in accordance with the GHG Protocol. The target does not include buildings outside the mill areas or internal logistics, as their share of emissions is assessed to be non-material. The baseline year is 2018, which was selected because it was a year of steady production, thus representing a normal year very well. The target will be reviewed at least every five years, starting from 2030.

Biogenic carbon dioxide emissions are generated from wood- based fuels and include only Scope 1 associated biogenic carbon dioxide emissions. A carbon dioxide emission factor of 396 tonnes of CO 2 /GWh, provided by Statistics Finland, has been used in their calculation.

The materiality of each of the 15 Scope 3 categories has been determined using a spend-based materiality assessment. All the categories assessed as material are calculated. Categories in which the amount of greenhouse gases was insignificant were also included in the Scope 3 inventory. The categories included in the calculation are listed in the table on GHG emissions. Only three categories have been excluded from the calculation – upstream leased assets, downstream leased assets and franchis- ing – as they were assessed as non-material. Metsä Board does not have significant leased assets under Scope 3 that would not already be included in Scope 1 and Scope 2. Metsä Board does not engage in franchising. All the Group’s companies are included in the calculation.

The Scope 3 inventory has been calculated as tonnes of CO 2 equivalent, excluding biogenic CO 2 . For biogenic Scope 3 carbon dioxide emissions, the emissions resulting from biomass sold for energy use (Category 11) have been calculated and reported sep- arately (58,012 tCO 2 e in 2025). The reporting is subject to uncer- tainty due to the limited data available, and the reporting will be further developed in future reporting periods. The operational data used in the calculation are obtained from Metsä Group’s internal systems. In the absence of accurate data, assumptions have been used. The emission factors used are mainly from global databases, including ecoinvent 3. 12, EXIOBASE 3, DEF-RA’s GHG conversion factors (full set 2022) and IEA v8 - IEA 2025 (11/2025). In category 4, “Upstream Transportation and Distribu- tion”, supplier-specific emission factors have been used for 79% (56) of Metsä Board’s activity data. In category 1, “Purchased Goods and Services”, supplier-specific emission factors have been used for 82% (81) of raw materials and packaging materials included in Metsä Board’s purchases (excluding raw wood). To improve accuracy, we aim to collect supplier-specific emission factors when they are available. Emission factors are reviewed annually to ensure that the latest emission factors are used.

Regarding purchased goods and services, in the absence of accurate data, assumptions and generalisations have been made in the selection of a suitable emission factor for specific purchase categories or individual materials and services, for example. Assumptions have also been made for raw materials and packaging materials when converting them from different units to tonnes, where average conversion factors have been used in the absence of product-specific data.

Some of the supplier-specific emission factors in logistics only cover CO 2 in current calculations, but they will be updated to include other material greenhouse gases in the next few years as the international disclosure guidelines for logistics develop. Currently, many of the supplier-specific emission factors in logistics only cover TTW (tank-to-wheel) emissions. As a rule, WTW (well-to-wheel) emission factors are used if available from suppliers. In the case of suppliers and transport routes for which supplier-specific emission factors are unavailable, the library

factors considered most suitable have been used. The selection of emission factors involves assumptions of the transport mode and more specific type of transport fleet based on the available activity data, for example.

In the absence of accurate data when calculating the processing of sold products, assumptions have been made of the processing methods of products sold to customers. The Group’s calculations are not based on primary data collected from customers. Suitable emission factors have been chosen for the assumed product processing methods.

The products’ waste treatment methods have been estimated based on publicly available location-based waste treatment data, including statistics (Eurostat, Statista, state statistical offices) and studies (EPA, PEFCR, ResearchGate, MDPI), as well as the Group’s information about the products’ sales areas. The Group’s calculations are not based on primary data collected from customers or end-users, and in the absence of accurate data, assumptions have been made on the final waste treatment methods of products sold based on the sales areas and publicly available waste treatment statistics.

Metsä Board’s investment emissions data are based on the company’s share of Metsä Fibre’s Scope 1 and Scope 2 emissions, corresponding to Metsä Board’s holding (24.9%) in Metsä Fibre, excluding the emissions associated with pulp raw materials procured from Metsä Fibre that have been assigned to the first category of the Scope 3 inventory.

Metsä Board has set a target to reduce greenhouse gas emissions in Scope 3, category 4, “Upstream Transport and Distribution”, by 30% per tonne-kilometre, relative to a 2022 baseline. The base year 2022 represents a normal year for business operations and is the first year for which Scope 3 emissions have been calculated using the current method. The regulatory impacts have been taken into account in setting the Scope 3 target. It has been assumed that regulation will promote the achievement of this target, as it encourages maritime and land logistics to use lower-emission fleets. In addition, regulation has increased the demand for low-carbon footprint products, especially in Europe. The metric includes all emissions calculated in category 4, which consist of product transport to customers paid for by Metsä Board, wood transport, port operations and storage, as well as transport of raw materials to Metsä Board that are not included in Scope 3, category 1 “Purchased Goods and Services” emissions. Transport emissions have been calculated using mode-specific emission factors based on average data such as the DEFRA data- base and factors collected from suppliers, and for port operations and warehouses, emission factors from the EXIOBASE database. The metric calculates the greenhouse gas emissions for each sub-area and divides them by the total tonne-kilometres of the corresponding transports. The intensity of transport emissions is monitored annually against the reduction target.

A more detailed description of calculation methods for Scope 3 emissions is available on Metsä Group’s website .

The metrics have not been validated by an external party.

53

E2 – Pollution

Pollution-related impacts, risks and opportunities

Impacts

Value chain stage

Time horizon

Risks and opportunities for Metsä Board

Value chain stage

Time horizon

Pollution of air, water and soil

In addition to greenhouse gases, production causes emissions to air, most of which originate from combustion processes in pro- duction and power plants. Production also generates wastewater discharges. The company has environmental liabilities related to former activities on industrial sites that have since been closed, sold or leased, and from decommissioned landfill sites.

Pollution of air, water, and soil resulting from technical faults or human error, which may be harmful to the environment, particularly due to repeated exceedances of emission limits laid down in environmental permits.

Risk: Abnormal emissions that may give rise to liability for compensation, the costs of corrective actions, and the impact on Metsä Board's reputation as a responsible operator

Opportunity: Verification of emissions minimisation to customers by using the best available techniques and certified management systems

Microplastics

Products produced mainly from renewable raw materials offer an alternative to plastic packaging and enable the reduction of microplastics.

Opportunity: Increase in the demand for Metsä Board’s products

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

Upstream value chain

Own operations

Downstream value chain

Short-term (less than one year)

Medium-term (1–5 years)

Long-term (more than 5 years)

Targets

Metsä Board does not have public targets related to pollution prevention, but the Environmental Protection Act and the emission limits defined in production units’ environmental permits guide operations, and thus encourage the prevention of environmental pollution or its limiting to a minimum. Production units have internal targets that are stricter than the emission permit conditions. In accordance with the Environmental Policy, negative environmental impacts are minimised, and environmental efficiency is improved by developing operations in compliance with the principles of sustainability and continuous improvement.

Material emissions to air, water and soil

Most of Metsä Board’s emissions to air originate in the pulp mills’ and power plants’ combustion process. The primary emissions are carbon dioxide, sulphur dioxide, nitrogen oxides and particles. Small amounts of reduced sulphur compounds are also generated at pulp mills. Their amounts are reduced with the meticulous control of combustion processes and purification of flue gases.

Wastewater discharges primarily consist of nutrients (phosphorus and nitrogen), organic substances measured as chemical and biological oxygen demand, as well as suspended solids. The wastewaters of pulp production also contain organic chlorine compounds, sodium and sulphates. Emis- sions to water are reduced by reducing water use, making processes more efficient and using efficient abatement technology.

The company generates very small amounts of heavy metal emissions to water and air, and most of the substances such as zinc and nickel originate from the wood raw material. Metsä Board’s normal operations do not generate emissions to soil containing heavy metals.

Policies

Metsä Board’s sustainability work related to pollution prevention is guided by Metsä Group’s Environmental Policy. Metsä Board is committed to protecting the environment and ensuring chemical safety, preventing envi- ronmental pollution and continuously developing production processes by employing the best available methods and techniques. The Environmental Policy is described in greater detail under G1 – Business conduct.

In the Forerunner in sustainability strategic programme, the environ- mental focus is on implementing the planned actions aimed at achieving the strategic sustainability targets in water and energy efficiency, for example.

Environmental management and continued environmental performance are guided by the requirements of the production units’ certified quality, environmental management and energy management systems. The production units’ environmental management practices are described in greater detail in the company’s internal environmental management policies. A key goal is to actively engage in preventive work, which is the most effective way of preventing leakage and disruptions. Production unit employees continuously observe their work environment, actively make environmental observations and take immediate corrective actions if required. Regular environmental walks are carried out at Metsä Board. In addition, employees are offered training and regular info sessions on environmental topics. The production units systematically conduct risk assessments and internal and external audits in accordance with the ISO 14001 and ISO 50001 standards.

All Metsä Board employees have the right and responsibility to report a situation that may cause a leakage or failure. Any infringement of environmental permit limits and significant deviations are investigated, and corrective actions are determined. The production unit’s management is always in charge of the investigations, as well as the adequacy and implementation of corrective actions.

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Report of the Board of Directors | Metsä Board Annual review 2025

The terms and conditions of maintenance and procurement project agreements for production unit sites contain minimum environmental requirements for goods and service suppliers. Suppliers are required to immediately report any observed hazards, accidents or other equivalent matters to Metsä Board’s contact person. Suppliers must participate in the investigation of any environmental deviation or damage resulting from their operations, determine corrective actions and take part in compensating for the damage in accordance with the applicable law and the “polluter pays” principle. Ways of ensuring suppliers’ responsibility are discussed in more detail under G – Governance .

Actions

Pollution of air, water and soil

Continuous actions

The best available techniques (BAT) are used in production, and environmental performance is monitored continuously. All Metsä Board production units have a valid production unit-specific environmental permit or equivalent official decision. The environmental permit and the related programme for monitoring emissions and impacts set the minimum requirements for the observation of environmental impacts. In addition to emissions, observations typically focus on waterbodies, fish stock, air quality and noise levels. Regular risk assessments and official inspections ensure the adequate scope of observations, the adequacy of the produc- tion unit’s performance and the prevention of disturbances. Any deviations and related corrective actions are immediately reported to the authorities. In 2025, no environmental pollution causing significant damage and corrective action occurred at Metsä Board. Furthermore, there were no significant chemical or other leaks resulting from the operations in 2025.

Environmental permits and the best available techniques are also ways to consider stakeholders living in the vicinity of production units in pollution prevention. More information about engaging with stakeholders is provided under S3 – Affected communities . Production processes are developed in line with continuous improvement and targets. For example, emissions to air are reduced through careful control of combustion processes and flue gas cleaning, while emissions into waterways are reduced by minimising water consumption, and improving the efficiency of processes and wastewater treatment. Environmental impact assessments are conducted in process modification projects if required.

All Metsä Board production units come under the scope of the EU’s Industrial Emissions Directive and BAT conclusions. In addition, the main boilers of the production units’ power plants come under the scope of the EU’s Industrial Emissions Directive and the BAT conclusions concerning large combustion plants.

Actions taken during the reporting year

Emissions to air and water have, for the most part, decreased moderately compared with the previous year. This is the result of the general market situation and production limitations.

Optimisation of the Husum pulp mill’s bark boiler in 2025 will signifi- cantly reduce Husum’s nitrogen oxide emissions. Water recycling from the Kemi paperboard mill for the production of unbleached pulp, as well

as the renewed oil separator and water distribution system at the Simpele paperboard mill, aim to reduce water withdrawals and wastewater to the wastewater treatment plant. In addition, the new oil separator reduces the risk of oil pollution. The BCTMP mill in Joutseno improved the process for washing wood chipper rejects to reduce raw material waste, as well as the solids load and chemical oxygen demand in wastewater treatment. In 2025, no significant capital or operating expenditure was allocated to key actions to prevent pollution.

Microplastics

Metsä Board’s products do not contain microplastics, but some of the products used for industrial purposes at production units contain compo- nents classified as microplastics. For example, the Husum paperboard mill has an extrusion coating line where food service boards are coated with polyethylene (PE). The waste material generated in coating is recovered and delivered to cooperation partners for reuse. In its packaging materials, Metsä Board uses plastic and kraftliner to protect the finished paperboard products during storage and transport.

Metsä Board’s products, produced mainly from renewable raw materials, already offer an alternative to plastic packaging and enable the reduction of microplastics. The products are described in greater detail under E5 – Resource use and circular economy .

Financial effects

In 2025, Metsä Board’s environmental liabilities totalled EUR 0.9 (1.9) mil- lion, and its environmental expenses amounted to EUR 12 (15) million . The environmental expenses consist mainly of expenses related to the use and maintenance of environmental protection equipment, expenses related to waste management and environmental insurance, and the depreciation of capitalised environmental expenses.

The company has environmental liabilities related to former activities on industrial sites that have since been decommissioned, sold or leased, and from closed landfill sites. Financial provisions for the costs of land rehabilitation work have been made in cases where it has been possible to measure the company’s liability for land contamination and any post-treat- ment obligations. The provisions total EUR 0.7 (1.7) million.

The pollution-related risks and opportunities identified in the materiality assessment are presented in the table on page 54 . The likelihood of signif- icant accidental discharges is low due to the control measures in use, and no material financial effects such as compensation or depollution costs are known of or reasonably expected.

No significant environmental impacts, claims or compensation related to the pollution of air, water and soil were recorded in 2025, nor was there any significant media visibility related to these topics. Environmental permit deviations are presented in a table under Metrics .

55

Metrics

Environmental permit deviations at Metsä Board’s mills

Mill

Time of incident

Incident

Corrective action

Äänekoski

1/2025

Solids reduction at wastewater treatment plant fell below monthly permit limit

More precise process adjustment

Äänekoski

2/2025

Solids reduction at wastewater treatment plant fell below monthly permit limit

More precise process adjustment

Äänekoski

5/2025

Solids reduction at wastewater treatment plant fell below monthly permit limit

More precise process adjustment

Kyro

7/2025

Three instances of daily permit limit exceedances for HCl and CO emissions to air from the power plant

Production stabilisation

Kaskinen

8/2025

Exceedance of monthly permit limits for phosphorus and nitrogen at wastewater treat- ment plant

Better chemical management

Kyro

10/2025

Exceedance of the monthly permit limit for NO x emissions to air from the power plant

More precise process adjustment

Kyro

10/2025

Seven instances of daily permit limit exceedances for NO x and CO emissions to air from the power plant

Boiler shutdown for the renewal of the platform

Kyro

10/2025

Two instances of daily permit limit exceedances for CO emissions to air from the power plant

More precise process adjustment

There were 17 exceedances of environmental permit limits. No deviations causing a significant environmental impact.

Emissions to air

t

2025

2024

Sulphur dioxides (SO 2 )

155

184

Nitrogen oxides (NOₓ)

1,068

1,363

Fine particulate matter (PM2,5)

31

33

kg

2025

2024

Ammonia (NH₃)

52,368

59,360

The table includes only the emissions from those production facilities that exceed the facility-specific threshold value defined in Annex II of Regulation (EC) No 166/2006.

Emissions to water

t

2025

2024

Adsorbable organic halides (AOX)

40

45

Chemical oxygen demand (COD)

9,976

9,743

Biological oxygen demand (BOD)

762

635

Phosphorous (P)

19

22

Nitrogen (N)

134

156

Suspended solids

1,366

1,662

kg

2025

2024

Arsenic (As)

24

29

Chromium (Cr)

0

148

Copper (Cu)

0

60

Nickel (Ni)

0

204

Lead (Pb)

0

31

Zinc (Zn)

140

2,566

The table includes only the emissions from those production facilities that exceed the facility-specific threshold value defined in Annex II of Regulation (EC) No 166/2006.

Reporting principles for metrics

Emissions to water and air include the material emissions from Metsä Board’s production units. Discontinued lines are included in the calculations for as long as they are used in production. Emissions are also reported to the authorities.

Water discharges are determined based on laboratory meas- urements. Emissions to water are calculated as a combination of waterflows and concentrations. Any wastewater discharges of third parties handled in the wastewater treatment plants are excluded from reporting. Emissions to air are determined based on continuous and/or one-off measurements. The final emissions are calculated as a combination of airflows and concentrations.

Emissions are allocated to internal and external inflows by first making an assumption, based on prior measurements, of the reduction in chemical oxygen demand (COD) for each inflow, and later adjusting them to correspond to the unit’s actual COD reduction. Other emissions are allocated based on the flow. At integrated mills, the amount of COD is allocated to parties using the wastewater treatment plant based on the quality of COD. Discharges fed through external (usually municipal) wastewater treatment plants are taken into account with the assumption of an 85% reduction in COD.

Limitations of measurements based on flow measurements are discussed under E3 – Water and marine resources .

Biological oxygen demand (BOD) and emissions of phosphorus and suspended solids are calculated based on the flow, using the following residual concentrations: BOD 10 mg/l, total phosphorus 0.5 mg/l and suspended solids 10 mg/l. Total nitrogen emissions are considered to be zero, as municipal wastewater contains excess nitrogen, and the reduction of BOD binds nitrogen to bio- mass, reducing the unit’s total nitrogen emissions. A seven-day measuring period (BOD7) is used to determine BOD.

Heavy metal reporting is conducted annually using the latest available analysis data and flow rates. The analysis frequency var- ies between production units, which is why not all measurement results are from the reporting year.

The metrics have not been validated by an external party.

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Report of the Board of Directors | Metsä Board Annual review 2025

E3 – Water and marine resources

Impacts, risks and opportunities related to water and marine resources

Material sub-sub-topics

Impacts

Value chain stage

Time horizon

Risks and opportunities for Metsä Board

Value chain stage

Time horizon

Water

Water withdrawals

Metsä Board’s production units are located in areas of low or low-medium water risk that have large surface water reserves. The operations are designed so they do not limit other parties’ rights or opportunities to use water.

Opportunity: The production units’ location in areas of low water risk, which supports the Group’s competitiveness in a changing climate. Cost benefits from reduced process water consumption, improved energy efficiency and water risk minimisation. The reduced need for clean water and recycling of pro- cess water in production processes reduce the water load on natural waters and improve Metsä Board’s reputation as a responsible operator.

Water consumption

The production process for pulp and paperboard products requires large amounts of water, but wa- ter consumption is low in relation to the amount used. Approximately 95% of the water is returned to waterways after use, and approximately 5% evaporates into the air or binds to products.

Risk: Failure to reduce water consumption in line with the target, which prevents cost benefits being realised and water risks from being minimised, and weakens Metsä Board's reputation as a responsible operator.

Wastewater discharges

Wastewater discharges from production and the potential local heat load from cooling water returned to waterways (water emissions described in section E2 – Pollution ).

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

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

Upstream value chain

Own operations

Downstream value chain

Short-term (less than one year)

Medium-term (1–5 years)

Long-term (more than 5 years)

Metsä Board’s 2030 sustainability target

2030 target

2025

2024

2023

2018

Reduction in process water use per produced tonne from the 2018 level, %

-35

-6.4

-11

+3,5

21 m³/t

The production line for unbleached pulp in Kemi, which became the property of Metsä Board in 2024, has not yet been included in the calculations concerning water and energy efficiency targets.

Metsä Board’s strategic 2030 sustainability targets, and their setting and monitoring, are discussed in greater detail under Sustainability governance and strategy and Material sustainability-related impacts, risks and opportu- nities . The company’s target concerning water resources is based on esti- mates of what can be achieved with the best available techniques (BAT). The use of the best available techniques is discussed under E2 – Pollution . In addition to the company-level target, all production units have targets for water use, which are regularly monitored.

Progress in target

Reduction in process water use per produced tonne from the 2018 level − In 2025, shutdowns at mills due to the market situation and investments weakened the efficiency of process water use despite the development measures taken.

Policies

Metsä Board’s water resource management and environmental targets are guided by Metsä Group’s Environmental Policy. Resource efficiency is a key part of the policy, and Metsä Board is committed to reducing its water use in line with sustainability targets. Wood supply is described in greater detail under G1 – Business conduct .

In the environmental permits of production units, attention is paid to water resources and their adequacy. Environmental management and

continued environmental performance are guided by the principles of the production units’ certified quality, environmental and energy management systems, as well as environmental management principles. The production units conduct planned risk assessments, as well as internal and external audits, in accordance with the ISO 14001 and ISO 50001 standards.

Metsä Board does not have separate policies or practices related to seas and oceans, as it does not use sea water in its production process.

In the Forerunner in sustainability strategic programme, the environ- mental focus is on implementing the planned actions aimed at achieving the strategic sustainability targets in water and energy efficiency, for example.

Policies related to water discharges are discussed under E2 – Pollution .

Actions

Continuous actions

Metsä Board’s water consumption is low in relation to the volume of water used. Of all the water consumed, approximately 95% (95) is returned to waterbodies after use, and the remaining 5% (5) evaporates in the pro- cesses or is bound to the products. The best available techniques are used in production, and environmental performance is monitored continuously. Increasing the efficiency of water use supports the circular economy and energy efficiency and minimises emissions. Metsä Board’s actions to

57

reduce process water use in line with the 2030 sustainability target include investments in processes and wastewater treatment, as well as process development to use less water. The actions improve water recycling and reduce water withdrawal from waterbodies.

The impacts, risks and opportunities, as well as management methods related to wastewater discharges, are discussed under E2 – Pollution .

Actions taken during the reporting year

The efficiency of water use was enhanced by actions to improve water recycling in Kemi and Simpele, for example. The actions are discussed in more detail in section E2 – Pollution Actions . Other actions to enhance water use were carried out as changes to operating methods or training for employees. In 2025, no significant capital or operating expenditure was allocated to key actions to enhance water use efficiency. To achieve its 2030 target, Metsä Board has mill-specific plans for investments to improve the efficiency of water use. The investment decisions will be made over the coming years.

Financial effects

As Metsä Board’s production units are located in areas at low water risk, no water-related expected financial effects were identified in the materiality assessment or in the analysis of climate change-induced physical risks conducted as part of the materiality assessment. The production units’ close proximity to abundant surface water reserves is an opportunity for the company in the management of climate-change-induced physical risks, for example. Increasing the efficiency of water use also affects energy efficiency, thus enabling cost savings.

Metrics

Water withdrawals and consumption and wastewater discharges

1,000 m³

2025

2024

WATER WITHDRAWAL

Surface water

84,938

105,796

Groundwater

27

33

Total water withdrawal

84,965

105,829

WATER CONSUMPTION

Water consumption

4,333

5,189

WATER INTENSITY (water consumption m³/EUR turnover)

Water intensity

0.003

WASTE WATER FLOW

Waste water flow

44,460

48,540

The turnover used in water intensity calculations can be found in the consolidated finan- cial statements under Consolidated statement of comprehensive income.

Reporting principles for metrics

Water withdrawals and consumption

Water withdrawals include the water withdrawn at Metsä Board’s production units for production and cooling.

Water consumption is an estimate of the amount of water that has evaporated in production and wastewater treatment, and water bound in products and wastewater treatment sludge. The calculation is based on an estimate, which considers the matters mentioned above, as well as direct water withdrawal, the water contained in raw materials and the water returned to waterbodies.

Process water means the water moved from the production process to wastewater treatment. Process water use per tonne produced is based on continuous measurements and is calcu- lated from the process water used as cubic metres per tonne of product produced.

All process water directed to treatment circulates at least once. The most relevant factors in this context are the amount of process water withdrawals and the amount of water conveyed to the treatment plant (m³/tonne of product). The volume of stored water is not disclosed due to non-materiality: as a rule, water is not stored.

Wastewater

Wastewater is cleaned water returned to waterbodies after the wastewater treatment process. In addition to process water, the volume of treated wastewater includes other water generated by wastewater treatment.

At Metsä Board’s production units, the flow of wastewater discharges is determined with continuous flow meters. The measurement of wastewater load is described in more detail on page 33 .

Measurements based on flow meters carry a margin of error. However, the flow meters are regularly calibrated, and the meas- urement results are also controlled by the supervisory authority.

Discontinued lines are included in the calculations for as long as they are used in production.

The metrics have not been validated by an external party.

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Report of the Board of Directors | Metsä Board Annual review 2025

E4 – Biodiversity and ecosystems

Material impacts, risks and opportunities related to biodiversity and ecosystems

Impacts

Value chain stage

Time horizon

Risks and opportunities for Metsä Board

Value chain stage

Time horizon

Direct impact drivers of biodiversity loss

Climate change: Climate-warming greenhouse gas emissions from Metsä Board's production

The risks, opportunities and actions related to climate change are discussed under E1 – Climate change .

The company’s biogenic carbon dioxide emissions classified as carbon-neutral.

Pollution: The emissions to water, air and soil from production units that can have a negative impact on species and ecosystems in the area.

The risks, opportunities and actions related to pollution are discussed under E2 – Pollution .

Nutrient, suspended solids, humus and metal load in small waters and waterways caused by wood supply activities, which results in eutrophication or darkening of waterbodies

Risk: Weakening of Metsä Board’s reputation as a sustainable opera- tor particularly among local communities.

Land-use changes: A new production unit takes up space from any natural environment originally on the site.

Risk: Weakening of Metsä Board’s reputation as a sustainable opera- tor particularly among local communities.

Direct exploitation: Metsä Board uses wood as its raw material but does not own any forests that are significant for wood supply. The majority of wood raw material is sourced from forests, whose use is decided by the forest owner.

Risks are discussed under Impacts on the state of species and the extent and condition of ecosystems .

Impacts on the state of species and the extent and condition of ecosystems

Commercial forest use reduces the amount of dead wood and changes forest structure, which leads to changes in the state of species and the condition of ecosystems.

Risks:

Regulation that emphasises the protection of forest nature to promote biodiversity restricts felling volumes or increases wood supply costs

A complex regulatory environment that sets conflicting require- ments for the forest industry

Ecological compensation, which may increase the protection of commercial forests, as industries exploiting non-renewable materi- als strive to compensate their negative impacts while continuing to use non-renewable materials

Consumers' perception of forests as protected areas, which may reduce consumption of wood-based products

If the state of nature continues to weaken, the legitimacy and ac- ceptability of the forest industry, as well as the reputation of Metsä Board and Metsä Group as sustainable operators, will suffer.

Metsä Group aims to measurably and verifiably strengthen the state of nature by 2030. If achieved, this will have a positive impact on the state of nature

Opportunities:

The improved state of nature and the comprehensive management of benefits obtained from nature, or ecosystem services, which make forests more able to adapt to climate change.

Improvement of Metsä Board's reputation as a responsible operator as a result of operating in compliance with the principles of regener- ative forestry and success in strengthening the state of nature

Drainage of peatland forests, causing changes in habitats and potentially reducing biodiversity

Risk: Regulation that emphasises the special role of peatlands as large carbon reservoirs, sources of GHG emissions, and potential restoration and protection sites restricts felling volumes.

If valuable habitats or endangered species are not identified or taken into account in wood supply and forest management, fewer forests will offer special ecological value, and the number of individuals representing endangered species will decline

Risk: Failure to take valuable nature sites into account in felling prac- tices, which may damage Metsä Board's reputation as a responsible operator committed to the development of regenerative forestry

Risk: The use of fresh fibre in products with a short life cycle is associ- ated with biodiversity loss, which may negatively affect the reputation and market position of Metsä Board and Metsä Group, as well as the price of their products and their employer image, and possibly forest owners’ willingness to sell wood to Metsä Group

Biodiversity and the condition of waterbodies improve outside commercial forests.

Opportunity: Strengthening of Metsä Board and Metsä Group’s reputation as responsible operators

Consumer products based on native wood species

Opportunity: Regenerative forestry, which offers a competitive advantage over competitors who use non-native tree species in their products

Biodiversity plans for production unit sites, which increase biodiversity, taking special local features into account, and combining local industrial history and nature solutions

Opportunities:

Strengthening of Metsä Board and Metsä Group’s reputation as responsible operators

More comprehensive monitoring of the environmental impact of production units by including the built environment’s biodiversity impacts in monitoring

Improved cooperation with significant stakeholders in the localities of production units.

59

Impacts

Value chain stage

Time horizon

Risks and opportunities for Metsä Board

Value chain stage

Time horizon

Impacts and dependencies on ecosystem services

Material and non-material services provided by Finnish forests that have a local, regional, national or international impact. Commercial forest use that reduces the amount of dead wood and the number of old-growth trees, which leads to changes in the state of species and the condition of ecosystems

Risk: Weakening state of forest nature, which makes forests more vulnerable to weather phenomena caused by climate change

Risk: The development of ecological compensation models, which leads to increased protection of commercial forests

Metsä Group aims to strengthen the state of nature measurably and verifiably by 2030

Opportunity: Strengthening the state of nature and comprehensive management of the benefits derived from nature, i.e. ecosystem ser- vices, which improves the adaptation of forests to climate change and enables pollination services, wild harvesting, clean water, recreational use and carbon sinks. Mainstreaming regenerative forestry practices, bringing their full benefits to the fore in the industry and in public debate

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

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

Upstream value chain

Own operations

Downstream value chain

Short-term (less than one year)

Medium-term (1–5 years)

Long-term (more than 5 years)

Metsä Group’s 2030 sustainability targets for wood supply

2030 target

2025

2024

2023

MG: Retention trees on regeneration felling sites, %

100

96

97

96

MG: High biodiversity stumps on harvesting sites, %

100

98

92

MG: Spruce as the only tree species after young stand management, %

0

25

26

25

MG: Measures promoting biodiversity, number

10,000

10,616

6,586

816

MG: The target has been set at the level of Metsä Group.

The implementation of actions to promote biodiversity will be cumulative from 2023 onwards.

Metsä Group, which is in charge of Metsä Board’s wood supply, has strategic 2030 sustainability targets for promoting forest biodiversity and sustainable forest use, which are indirectly related to the promotion of biodiversity and ecosystems from Metsä Board’s perspective.

The 2030 sustainability targets address the impacts, risks and oppor- tunities related to biodiversity and ecosystems identified in the materiality assessment, and their main purpose is to prevent and minimise harm. The targets apply only to Finland, whereas international wood supply is also taken into account in calculating the forest certification rate. The targets focus particularly on the impacts, risks and opportunities identified in the upstream of the value chain. The targets are not based on a scientific framework, but they are aligned with the goals for curbing biodiversity loss stated by the UN, the EU and Finland. The targets do not include external ecological compensation, and in the absence of suitable threshold values, no ecological threshold values have been used in target-setting to date.

Regenerative forestry is a science-based, goal-oriented action programme aimed at strengthening the state of nature. The 2030 sustain- ability targets for wood supply are part of the goal of regenerative forestry, which aims to strengthen the state of nature. Practical activities and their development are guided by targets, actions and verified results. The 2030 sustainability targets for wood supply have been shaped by nature man- agement actions linked to forestry practices. By monitoring these actions, it is possible to verify the achievement and progress of operational targets.

The action plans for achieving the targets are scientifically justified. Forest management, support for forest biodiversity, and forest thinning make forests more vigorous and resilient against climate change-induced weather phenomena or insect damage, for example. Metsä Group also repairs and restores nature sites that have suffered from any damage. For

example, management measures on sunlit slopes and in herb-rich forests support the restoration of biodiversity. The goal is to increase the number of species on sites allocated to production by diversifying tree species and adding decaying wood, for example.

The identification and assessment of material impacts, risks and opportunities

Risk management as part of wood supply and forest services operations

Metsä Board’s impacts, risks and opportunities related to forest biodi- versity and the condition of forest ecosystems take place through Metsä Group’s Wood supply and forest services. Metsä Group’s wood supply is not based on the company’s own forests. In Finland, most of the wood is acquired from Metsäliitto Cooperative’s owner-members, who together own around half of Finnish private forests and 32% (32) of all the forests in Finland. In Sweden, wood is mainly procured from Norra Skog’s own- er-members, who own around 10% (10) of all the productive forest land in Sweden. The certified ISO 14001 environmental management system used in Metsä Group’s wood supply guides operations towards environmental targets and supports risk management as part of daily operational work.

The assessment of nature risks is part of the wood trade process. The authorities are informed about harvesting plans with forest use declarations, and the authorities notify the company if any legislative requirements must be considered when carrying out harvesting. In addition to legislation, the requirements of forest certification systems are followed when planning and implementing harvesting. Metsä Group has a comprehensive, continuously maintained geospatial dataset that

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Report of the Board of Directors | Metsä Board Annual review 2025

is used in wood trade offers and deals, and in planning and implementing harvesting. The geographic information system enables the identification of sites at risk and geospatial analyses. The geographic information system is also used to update environmental data such as registers of endangered species and data about real estate, groundwater areas and waterbodies in real time for use in work guidance.

Regulatory impacts on forest use are one of the identified risks in Metsä Group’s wood supply. Regulatory risks are identified and assessed in accordance with Metsä Group’s standardised risk management process, and they are regularly assessed. Risks are identified, assessed and man- aged in cooperation with Metsä Group’s Wood Supply and the Stakeholder Engagement unit.

Risk management as part of investments and production units’ operational activities

Metsä Board’s production units may have negative impacts on the produc- tion unit sites’ biodiversity and ecosystems due to the units’ emissions and land use. The environmental impacts of production units are identified and assessed in the environmental permit process. The need for environmental impact assessments is ultimately determined by the local EIA authority. The impacts on conservation areas and Natura sites are considered in the

assessment. If required, a Natura assessment is carried out in accordance with the specified procedure, and in large projects, a separate environmen- tal impact assessment preceding the environment permit process is also carried out. After any environmental impact assessment, the production units operate in accordance with their environmental permit and the company’s operational management system. The methods for identifying and managing the impacts of pollution are discussed under E2 – Pollution .

Stakeholder engagement

The results of the operating model for stakeholder engagement are considered in the sustainability materiality assessment and identification of biodiversity risks. The engagement of stakeholders in wood supply is discussed under Policies . The engagement of local communities in the production units’ operations from an environmental perspective is dis- cussed under E2 – Pollution . A general description of the operating model for the engagement of stakeholders, as well as processes for managing stakeholder engagement, can be found under S3 – Affected communities . Stakeholders have been extensively and actively involved in the resilience analysis. Stakeholders have participated in initiatives related to regenera- tive forestry and land use, for example.

Areas valuable to biodiversity in the vicinity of Metsä Board’s production units

Production unit

Total surface area owned

Name of area valuable to biodiversity

Protection type of area valuable to biodiversity

Distance from Metsä Board's production unit

Metsä Board's impact on the area

Kemi

11 ha*

Perämeri National Park,

Kallinkangas, Kaltiojänkä herb-rich forest, Kirvesaapa

Natura 2000 sites (the National Park is also a state nature reserve)

6–10 km

Mild indirect combination impacts from eutrophica- tion on the Perämeri National Park. The ecological state of surface waters in the area is satisfactory. No direct impacts on buffer zones and thus on the protected habitats or species. Estimated combined impact with Metsä Fibre’s bioproduct mill.

Kaskinen

180 ha

Närpes Archipelago, Kristiinankau- punki archipelago, Bredmossmyran nature reserve

Natura 2000 sites (and several areas in the Närpes archipelago included in nature conservation programmes)

2–10 km

Mild indirect combined impacts from eutrophication on the Närpes and Kristiinankaupunki archipelagos 2–5 km from the production unit. The ecological state of surface waters in the area is satisfactory. No impacts on the habitat types or species forming the basis for Natura protection.

* Metsä Group owns a total of 1,787 ha of the Kemi production unit site, and of this, 1,776 ha is in Metsä Fibre’s ownership.

Consideration of biodiversity and ecosys- tems in the strategy and business model

Metsä Board’s wood supply is handled by Metsä Group’s Wood Supply and Forest Services. The resilience of Metsä Board’s strategy and business model has been assessed by identifying material risks related to biodiversity and ecosystems and by assessing how effective Metsä Group’s long-term actions aligned with the regenerative forestry and land-use principles are in managing the risks in question. The material risks are pre- sented in the table on pages 59–60. Key uncertainty factors identified in the resilience analysis include the weak predictability of EU legislation and the climate change adaptation of complex natural ecosystems, which are discussed in greater detail under E1 – Climate change . The implementation of the materiality assessment and the periods used in it are described on pages 31–34 .

Resilience has been assessed in the company’s own operations and in the value chain. The key risks related to biodiversity and ecosystems concern the wood supply chain. The assessment of business risks

fundamental in the resilience analysis is based on the climate scenarios also used in the climate risk analysis and on the scenarios in the wood processing industry’s biodiversity roadmap.

In Finland, the climate change scenario means significantly faster cli- mate warming than the global average. As Finland also has a very long tree rotation period in global terms, adapting to climate change is a key issue for forest resilience. General research data suggests that diverse ecosystems are better able to adapt to changing conditions than monocultures with few species. Finland has therefore recognised the importance of nature-based solutions for adaptation to climate change.

The goal of a comprehensive identification and management of ecosystem services is to prepare for both transition and systemic risks and physical risks. The key risks are related to forest use regulation and climate change-induced physical risks, among other things. Increasing biodiversity plays an important role in forests’ climate change adaptation.

The goal of regenerative forestry is to develop forest management so that the various ecosystem services can be identified and measured, and

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wood is produced as part of a common production model for ecosystem services. The key identified factors strengthening the resilience of Metsä Group’s business are:

A production model based on native tree species and not requiring changes to land use, which is an important part of business resilience in terms of ecosystems, biodiversity and climate change.

Increasing the value of the forest assets of Metsäliitto Cooperative’s owner-members and transferring forests in a stronger state from one generation to the next are key elements of Metsä Group’s strategy and owner-member strategy. The value potential of a diverse and multispe- cies forest is greater than that of a forest that is poorer in nature value.

Securing comprehensive ecosystem services not only recognises the carbon balance but also those ecosystem services that are important for self-sufficiency and security of supply at the national level.

The importance of the functional diversity of forest ecosystems is recognised as important in regenerative forestry. Forest nature is an interconnected ecosystem in which producers, consumers and decom- posers are mutually dependent.

With its target of strengthening the state of nature, Metsä Group contributes to international, EU and Finnish biodiversity targets by being an example in the private sector.

Dialogue, cooperation and partnerships support the overall objectives of regenerative forestry and land use.

The impact of climate change on the state of nature and the role played by actions improving the state of nature are discussed under E1 – Climate change .

Policies

The work related to biodiversity and ecosystems is guided by Metsä Group’s Environmental Policy. In its policy, the company is committed to obtaining wood raw material from sustainably managed forests, and pay- ing attention to the economic, social and environmental aspects of forest management and wood supply. The company is committed to preventing pollution and continuously improving its production processes by utilising the best available methods and techniques. The Environmental Policy is described in greater detail under G1 – Business conduct .

Wood supply and forest services

Metsä Group, which handles Metsä Board’s wood supply, adopted the regenerative forestry principles in 2023 as a continuation of Metsä Group’s ecological sustainability programme for safeguarding biodiversity. Regen- erative forestry aims at a set of measures that will verifiably strengthen the state of nature in Finland. The wood supply strategy is based on wood production that does not involve land-use change, and in which the number of native species is very high despite production. Metsä Group has measured the state of nature and its development in collaboration with researchers, using the best available data. Science-based indicators and the development of monitoring are key development measures for the reliability of measured data. The regenerative forestry programme was approved by Metsäliitto Cooperative’s Board of Directors, and it was presented to all owner-members.

Forest certification can be used to demonstrate that forests have been managed sustainably and responsibly. Forest certification has two key

elements: sustainable forest management and the wood supply chain. The international forest certification systems used by Metsä Board are PEFC (Programme for the Endorsement of Forest Certification, PEFC/02−31−92) and FSC® (Forest Stewardship Council, FSC-C001580).

Metsä Group’s principles for forest use and management are publicly available. All the wood is procured from either certified forests or forests that meet the requirements of controlled origin (PEFC Controlled Sources, FSC Controlled Wood). The origin of the wood is always known. The attention paid to biodiversity in forestry is comprehensively noted in certification systems. Certification systems help recognise and restrict measures harming biodiversity by defining sites that must always be saved and excluded from operations, for example.

The procurement of Metsä Board’s wood does not cause deforestation. All the countries from which wood is procured have issued legislation requiring forests to be renewed after felling. The wood that Metsä Board uses in its products is mainly procured from Finland, Sweden and the Baltic countries. Wood supply by country is specified in the table in section G1 – Business conduct . Metsä Group requires all its partners to comply with legislation, and operations adhere to the European Timber Regulation (EUTR), US Lacey Act and UK Timber Regulation (UKTR). In 2025, Metsä Group has continued to update its due diligence system to comply with the requirements of the EU’s Deforestation Regulation (EUDR). Wood supply is described in greater detail under G1 – Business conduct .

Metsä Group’s Wood Supply also considers the impacts of its operations on its key stakeholders, including forest owners, mill locations and their residents, nature, and people who earn their livelihood from nature, such as indigenous peoples (the Sámi), as well as other parties interested in the environment, such as NGOs. In the home region of the Sámi, Metsä Group engages in local dialogue about the coordination of reindeer husbandry and forestry with key stakeholders such as forest owners and reindeer owners’ associations. Communication with the Sámi is typically related to practical questions. Reindeer owners’ associations in the home region of the Sámi have been identified as a local community to be engaged with.

Production units

Environmental management and the maintenance of environmental per- formance are guided by the requirements of the production units’ certified quality, environmental and energy management systems, as well as the principles of environmental management. The production units conduct planned internal and external audits in accordance with the ISO 14001 and ISO 50001 standards.

Metsä Group has also targeted the strengthening of the state of nature on the sites of its production units. Metsä Group’s regenerative land-use principles guide towards nature-based solutions in industrial environ- ments. To implement the operating model, a pilot phase of the project will be conducted at the Kemi integrated mill. Based on the experiences gained, we hope to integrate the activities at other mill locations. The goal is to make the improvement of biodiversity on production unit sites part of the production units’ environmental management, operations and reporting. The production units’ biodiversity roadmaps are discussed under Actions .

Policies related to water use and water discharges are described under E2 – Pollution and E3 – Water and marine resources . The engagement of local communities in the production units’ operations from an environmen- tal perspective is discussed under E2 – Pollution .

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Report of the Board of Directors | Metsä Board Annual review 2025

Actions

Actions related to climate change mitigation and adaptation, as well as pollution, are discussed under E1 – Climate change and E2 – Pollution . Metsä Board does not implement biodiversity actions itself, but they have an indirect impact on the company, as Metsä Group’s Wood Supply and Forest Management Services, which administer the actions, are also responsible for all Metsä Board’s wood procurement. In addition, Metsä Group’s Stakeholder Engagement unit, in cooperation with the mills and Metsä Board’s specialists, is responsible for other actions.

Wood supply and forest services

Wood raw material is used as efficiently as possible, ensuring high added value and minimising the forest area needed for harvesting. The utilisation of side streams is described in greater detail under E5 – Resource use and circular economy .

The targets of regenerative forestry are discussed under Policies . In the regenerative forestry programme, monitoring systems are developed jointly with stakeholders so that the impacts of operations on the state of nature can be measured and disclosed.

Continuous actions

Forest and nature management and harvesting methods are based on up-to-date research data and practical experience. Metsä Group actively cooperates with various research institutes. Some of the key biodiversi- ty-promoting measures that follow the principles of regenerative forestry include the following:

Wood is procured only from certified forests or sources of controlled origin, and certified wood is given priority. Metsä Group actively participates in the development of the international PEFC and FSC forest standards. Owner-members are offered the opportunity to certify their forests under the PEFC and FSC systems, and a higher price is paid for certified wood.

For industrial use, Metsä Group only procures tree species naturally occurring in the area – that is, spruce, pine, silver birch, downy birch and aspen. In their natural range and suitable growth sites, trees live in interaction with their many companion species.

More than 20 native broadleaved tree species are completely excluded from purchasing and processing. Thousands of companion species are associated with these tree species.

Mixed forests increase forest biodiversity and forest resilience against storm and insect damage, for example. Metsä Group offers forest owners a forest regeneration service in which both spruce and pine are planted in the same area. Broadleaved trees such as birch, which spreads at stands naturally, are also favoured in forests.

There are many ways to increase the amount of decaying trunk wood: by preserving dead trees; leaving retention trees; and creating high biodiversity stumps. The amount of decaying trunk wood is also being increased in valuable habitats outside the treatment area and in water protection zones.

Nature management measures or voluntary protection are recommended to owners of herb-rich forests. Nature management measures thus focus on places where they have the greatest impact on biodiversity. Protective thickets are left for animals at all stages of forest management.

The management of sunlit slopes improve the living conditions of species found in open ridge habitats. Managing sunny and hot slope sites means removing shading trees and exposing bare mineral soil.

Metsä Group’s nature site service helps focus the protection required by FSC on sites with the greatest nature value.

Buffer zones along waterbodies promote biodiversity and prevent the runoff of soil and nutrients. A buffer zone is a strip along a waterbody where forest management measures are performed more lightly or omitted completely.

Continuous cover forestry is chosen on sites for which it is suited.

In peatlands, the water balance and water quality of aquatic ecosystems are maintained and their species are protected by avoiding new drainage and only restoring drainage when necessary. Restoration sites are deter- mined on a case-by-case basis, and forest owners are offered the option of continuous cover forestry with additional bonuses. In the wood-trading process, nature risks are assessed using geographic information, and envi- ronmental data is taken into account in the planning and implementation of harvesting.

A very tangible example of the practical implementation of regenerative forestry measures is the Metsä Group Plus service, which is a forest man- agement model designed for Metsäliitto Cooperative’s owner-members. In the model, measures that safeguard and improve the state of forest nature more comprehensively than current standard practices are agreed in con- nection with wood trade and orders for young stand management. Under the model, more retention trees are left, and more high biodiversity stumps are made per hectare during felling. To accelerate the creation of decaying wood and to secure the living conditions of species that inhabit burnt environments, more retention trees will be burned. In valuable habitats and littoral forests, the service represents the highest level of requirements currently in use. Metsä Group pays a bonus per hectare for Metsä Group Plus wood to compensate any loss of wood trade income caused by the additional measures. The service was launched in 2023. In 2025, approxi- mately 30% of the wood in private forests that was sold through standing sales came from Metsä Group Plus sites. The costs incurred by the service are not reported, as they are sensitive information.

Metsä Group has actively participated in the drawing up and further development of a biodiversity roadmap for the wood processing industry in cooperation with other forest industry operators. The publicly available roadmap identifies the forest industry’s shared development areas, and the need for common indicators and monitoring systems. The roadmap outlines the development of forest biodiversity in Finland in recent dec- ades. Sample plot data from the National Forest Inventory and the national forest vegetation map were used as material.

With the roadmap, Natural Resources Institute Finland launched a VMI-Moni research project, which pilots the National Forest Inventory with additional new biodiversity indicators. Metsä Group is represented in the project steering group.

Natural Resources Institute Finland has also drawn up summaries of the state of forest nature and its development for Metsä Group’s own wood supply area in Finland. Moreover, model scenarios were made of the impacts that the Metsä Group Plus service has on biodiversity.

Metsä Board has identified the key legislative initiatives that may affect forest use and the production of Metsä Board’s products. As part of Metsä

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Group, Metsä Board participates in the management of regulatory risks by actively engaging in policy dialogue and targeting its key messages based on the identified regulatory risks. Advocacy is discussed under G1 – Business conduct . Regenerative forestry makes business more resilient to impacts related to legislation, the markets and climate change. It also helps implement a goal-oriented action programme to decouple the weakening of natural capital and economic growth.

In the planning and implementation of wood supply and forest services, and in forest certification, attention is also paid to safeguarding the rights of indigenous peoples in the Sámi home region and its vicinity. Metsä Group requires wood suppliers to consider the Sámi culture and reindeer herding in their forestry measures through agreements and their own assurance. Wood suppliers are also audited regularly. The attention paid to local communities and indigenous peoples in forestry is discussed in more detail under S3 – Affected communities . Indigenous peoples are heard as part of the continuous stakeholder interaction process, which is reported to the management every six months. In 2024, representatives of indigenous peoples were encouraged to engage in the human rights pro- cess and, based on this as well, their views were considered in the impact assessment results and the specification of development actions.

Actions taken during the reporting year

In 2025, Metsä Group announced that it would establish a foundation for protecting forests, which will begin operations in early 2026. The aim is to strengthen biodiversity. The foundation provides forest owners with financial compensation for sites whose protection supports national biodiversity targets. The protection criteria are drawn up based on nature conservation principles, and the permanent protection decisions will be based on legislation. The foundation’s conservation activities primarily focus on the forests owned by Metsä Group’s owner-members, but other Finnish forest owners can also apply to participate.

Production unit locations

Continuous actions

To develop an action programme for regenerative land use, the pilot project launched in Kemi in 2023 has been continued. To strengthen the state of nature, the pilot aims to develop a cost-effective operating model for built and industrial environments. The planning area in Kemi comprises the mill site and the surrounding land owned by the company. The special features of local nature will be taken into account in the action plan, and the living conditions of endangered species will be improved. The work carried out with an expanding cooperation network aims for internationally approved planning principles that will help improve the state of nature in the built and industrial environments independent of the sector. In 2025, Metsä Board did not incur any costs related to biodiversity plans and actions. The amounts spent by Metsä Board on pollution prevention actions are disclosed under E2 – Pollution . The aim is for the operating model to be expanded beyond the production sites, and for restorative land use to develop into an internationally recognised and accepted approach for enhancing nature. The costs of actions to be implemented in the coming years are still unknown.

Actions related to emissions to air and water discharges are discussed under E2 – Pollution .

Funding programme for nature projects

Actions taken during the reporting year

Metsä Group’s funding programme for nature projects annually funds regionally effective development projects that are conducted outside commercial forests in Finland, and improve biodiversity and the state of waterbodies. The funding programme is detached from Metsä Group’s own impacts and value chains, and it does not involve any compensations related to the company’s own environmental impacts. It aims to promote a new operating culture in nature-themed practical local cooperation. Communication between project participants, as well as annual meetings promote the development of theme-specific expert networks at the national level. Projects are selected for the funding programme once a year. In 2025, 22 (26) Finnish biodiversity management and restoration projects were selected for funding based on the recommendations of an independent panel, as follows:

Migratory fish and flowing waters: 5 projects

Wetlands and bird waters: 7 projects

Traditional landscapes: 1 project

Multi-objective projects: 9 projects

The funding for these projects totalled EUR 600,000 (600,000).

For example, in 2025, Metsä Group participated in the planning of the Luokas project together with the Finnish Environment Institute. This is a project aimed at developing the supply and market for wild plants, involving a wide range of participants. The availability of seeds and seedlings from natural plants would lead to significant cost savings in projects to restore built environments. Metsä Group is funding the Luokas project work package with EUR 90,000 from its nature project funding programme. The work package will create national criteria for reproductive material based on factors such as origin.

Impacts and dependencies on ecosystem services

Continuous actions

Wood production is one of nature’s key ecosystem services for Metsä Board. If the state of forest nature deteriorates, forests become more vulnerable to climate-change-induced weather phenomena and non-native species. Forests’ climate resilience will increase as a result of the comprehensive management of ecosystem services, or benefits obtained from nature, and regenerative forestry that improves the state of nature. The goal of Metsä Group’s forest management services is to safeguard locally, nationally and internationally significant ecosystem services. Forest owner-members have greater opportunities to create added value for their forest assets the more diverse the assets are when transferred from one generation to the next.

The key resources for actions related to biodiversity and ecosystems include the employees, development activities, system development and – indirectly – the machinery used in forestry work. The key resource for forestry measures is a comprehensive geographic information system of forests in the operating area.

To remedy any environmental deviations, Metsä Group offers voluntary nature compensation as part of regenerative forestry, which outweighs the harm to nature resulting from any violations of the law. The development

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Report of the Board of Directors | Metsä Board Annual review 2025

of the compensation model is underway, and it will be applied retroactively from 2023 to identified deviations. The compensation model is described in more detail under S3 – Affected communities .

Impact metrics related to biodiversity and ecosystems change

The 2030 targets providing a measure of the actions are described in the table Metsä Group’s 2030 sustainability targets for wood supply . Emissions to air and water discharges are discussed under E2 – Pollution . Metrics of the state of forest nature, their reliability and a harmonised monitoring sys- tem are developed as a collaborative industry effort and to achieve Metsä Group’s own targets. Further information can be found under Actions .

Financial effects

The risks related to biodiversity and ecosystems are presented in the table on pages 59–60 . As Metsä Group does not own forest important for its wood supply, the risks related to biodiversity and ecosystems do not affect its assets. If the risks were to be realised, they would affect Metsä Board in the long term through the availability and cost of wood raw material. The financial effects have not been assessed in detail at this stage, as reporting on them remains under development.

Reporting principles for metrics

The calculation of high biodiversity stumps left on harvesting sites covers the direct standing sales conducted by Metsä Group’s Wood Supply and Forest Services, meaning that delivery sales are not included in the calculation. The harvesting sites include intermediate and regeneration felling sites. The calculation of retention trees left on regeneration felling sites covers the direct standing sales carried out. Forest certification criteria set minimum requirements for the number of retention trees. The calculation is based on the number of regeneration felling sites. Stands containing only spruce after young stand management include the young stand management work carried out. The calculation takes spruce-dominated sites into account where spruce amounts to more than 50% of the remaining trees. Spruce is considered to be the only tree species if other species account for less than 10% of those remaining on the site.

The number of measures promoting biodiversity is calculated based only on the measures conducted in owner-members’ forests. The measures that are currently monitored include nature management measures in herb-rich forests, burned retention tree groups, Metsä Group’s FSC nature site service and the number of Metsä Group Plus agreements.

Metsä Group develops metrics for the state of forest nature, their reliability and a harmonised monitoring system. The development of metrics is described in more detail under Actions .

Metsä Group Plus sites were assessed by an external evaluator in 2025. The other metrics have not been validated by an external party.

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E5 – Resource use and circular economy

Material impacts, risks and opportunities related to resource use and the circular economy

Impacts

Value chain stage

Time horizon

Risks and opportunities for Metsä Board

Value chain stage

Time horizon

Resource inflows, including resource use

Thanks to regenerative forestry, the primary renewa- ble resources used by Metsä Board can be obtained in accordance with circular economy principles. They are a sustainable alternative to fossil raw materials.

Opportunity: Legislation that recognises the climate and other benefits of fossil-free raw materials in the production of materials and sets requirements for replacing primary fossil-based raw materials with more sustainable alternatives

Opportunity: The full use of the main raw material, renewable wood. The development of innovations, production processes and side streams, which can increase the added value of wood raw material and diversify the product portfolio

Risk: Legislation that requires the use of recycled material in bio-based products and does not recognise the circular economy benefits offered by fresh fibres that are important for the company. This could have a negative impact on business and may require new investments

The impacts, risks and opportunities related to wood-based energy are described under E1 – Climate change .

Resource outflows related to products and services

Metsä Board’s products offer customers and consumers a recyclable alternative to products made from fossil-based raw materials.

Opportunity: Legislation that favours recyclable products made from renewable materials over fossil-based alternatives, creating opportunities for growth

Risk: Legislation favouring reusable packaging or other reusable products over recyclable disposable products may reduce de- mand for Metsä Board's products. Furthermore, the introduction of chemical recycling of plastics on an industrial scale could increase the acceptability of plastics and reduce the need to replace them

Waste and side streams

New products processed from production side streams

Opportunity: Utilisation of side streams brings economic benefits, making full use of the forest industry’s side streams strengthens the industry’s acceptability and secures future operations

A small amount of landfill waste from production, causing emissions to air, water and soil, although the majority of production side streams are utilised as materials or energy

Risk: The appreciation of forest industry operations and economic benefits will weaken if a purpose is not found for all side streams

Risk: Legislation that leads to a decline in the use of forest industry side streams for bioenergy generation erodes the appreciation of forest industry operations

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

Upstream value chain

Own operations

Downstream value chain

Short-term (less than one year)

Medium-term (1–5 years)

Long-term (more than 5 years)

Metsä Board’s 2030 sustainability target

2030 target

2025

2024

2023

Process waste delivered to landfills, t

0

111

267

1,164

Metsä Board’s 2030 sustainability targets, and their setting and moni- toring, are discussed in greater detail under Sustainability governance and strategy and Material sustainability-related impacts, risks and opportunities . The target of 0 tonnes of process waste delivered to landfill, presented above, concerns resource outflows. The target is based on Metsä Group’s intention to steer all production side streams for reuse to eliminate all landfill waste. The target will be achieved by finding a use for all process waste. In the waste hierarchy, this is classified as waste recovery. Because the target’s achievement requires the utilisation of all side streams, it indi- rectly contributes to product design based on the circular economy. The utilisation of side streams is discussed in more detail under Waste and side streams . The target is indirectly related to increasing the utilisation rate of recycled materials through the use of side streams, but not to the sustain- able procurement and use of renewable resources, or to the minimising

of primary raw materials. Target-setting is based on compliance with leg- islation, as the target is based on the EU’s Waste Directive and the targets set in it. Comprehensive system-level metrics for the circular economy are under development internationally. Metsä Board follows the development of metrics and participates in related testing and development work.

The targets related to water and energy use are discussed under E1 – Climate change and E3 – Water and marine resources .

Progress in target

Process waste delivered to landfills – The reduction of Metsä Board’s landfill waste has progressed as planned towards the 2030 target. In 2025, only a single batch of process waste was delivered to landfill.

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Report of the Board of Directors | Metsä Board Annual review 2025

Policies

Metsä Board’s use of resources and the circular economy are guided by the operating principles defined in Metsä Group’s Environmental Policy. Metsä Board is committed to sustainable forestry, efficiently using raw materials, water and energy, and continuously developing operations. The side streams generated in production processes are used primarily as raw material or energy. The company takes advantage of synergies between its production units and develops industrial cycles and the recyclability of products. Wood supply is described in greater detail under G1 – Business conduct .

The production units’ certified quality, environmental and energy efficiency systems guide environmental management and environmental performance. The production units systematically conduct internal and external audits in accordance with the ISO 14001 and ISO 50001 standards.

In its operations, the company follows circular economy principles: safe- guarding nature’s capacity for renewal; minimising waste and emissions; and keeping natural resources used by society in use, both for as long as possible and as valuable as possible.

Because it is impossible to completely and permanently recycle and reuse materials, maintaining the material cycle also requires the addition of primary raw materials to the cycle. Fresh fibre is therefore needed to main- tain the well-functioning material cycle of fibre-based packaging. Primary renewable raw materials can be supplied in accordance with the principles of the circular economy from forests that are managed in accordance with the principles of regenerative forestry, for example. Metsä Group offers its owner-members a forest management model based on regenerative forestry, which is discussed under E1 – Climate change and E4 – Biodiversity and ecosystems .

In the Forerunner in sustainability strategic programme, the circular economy’s focus is on achieving the strategic sustainability targets for decreasing fossil-based carbon dioxide emissions, water and energy efficiency, and expanding the company’s role in the circular economy. The goal of the Efficient Innovation programme is to ensure the long-term competitiveness of Metsä Board’s products. Its focal areas include reduc- ing the weight of paperboard and developing recyclable products such as dispersion-coated paperboard.

All Metsä Board’s paperboards are produced from renewable and recy- clable fresh fibre. Fresh fibre paperboards do not interfere with the smell or flavour of the product inside, and they are a safe choice for fibre-based packaging for food and other demanding end uses.

Actions

Resources inflows, including resource use

Continuous actions

Raw materials are used resource efficiently to avoid production waste. The main raw material, renewable wood, is used fully. The most valuable part of the tree is the log, which is used in wood products manufactured by Metsä Group’s other business areas. Thinner tree parts and thin tree trunks obtained from thinning are the main raw materials for pulp and paperboard mills. The branches and felling residue are used in the production of renew- able energy. Metsä Board’s mills are continuously improving their recovery

processes to avoid the generation of waste in pulp and paperboard production. For example, increasing process water recycling makes energy use more efficient and reduces the loss of fibre material.

Metsä Board’s key actions related to resource inflows and use are the following:

As part of Metsä Group, committing to principles of regenerative forestry and promoting regenerative land use on mill sites. This action improves the state of forest nature and biodiversity in built environments. Further information is available under E1 – Climate change and E4 – Biodiversity and ecosystems .

Reducing water use by developing production processes and deploying new techniques. Further information is available under E3 – Water and marine resources .

Transitioning to fully fossil-free energy in production to reduce fossil-based GHG emissions. Further information is available under E1 – Climate change .

Improving energy efficiency by using electricity, heat and fuel more efficiently. Further information is available under E1 – Climate change .

Outflows related to products and services

Continuous actions

In the circular economy for fibre-based packaging material, Metsä Board’s task is to provide markets with premium fresh fibre paperboards as resource-efficiently as possible, help replace fossil-based materials and reduce the carbon footprint of packaging. Ensuring and developing the recyclability and compostability of paperboards is of key importance

The company’s R&D focuses on reducing the weight of paperboard and developing a bio-based barrier coating for end uses in food packaging. Further information is available in the Board of Directors’ report, under R&D and innovation .

Metsä Board’s key actions related to products and services are the following:

Reducing the environmental impacts of packaging through product development such as reducing the weight of paperboards, and offering customers services to reduce environmental impacts across the life cycle of packaging. Through its 360 Services, Metsä Board offers cus- tomers services in fields like R&D, sustainability and packaging design to help customers improve the recyclability and material efficiency of their packaging through life cycle calculations, data-based comparisons of the environmental impacts of different materials, and tangible packaging solutions. In 2025, Metsä Board has conducted mill trials to reduce the weight of paperboard and worked with customers to design packaging concepts that reduce resource use.

Recycling is promoted by participating in international initiatives. Par- ticipation in international initiatives contributes to a stronger European and global circular economy, and to Metsä Board’s products remaining in circulation longer. Metsä Board is one of the founding members of the 4evergreen initiative, launched in 2019. 4evergreen brings together members across the packaging value chain with a goal of raising the recycling rate of fibre-based packaging in the EU to 90% by 2030. Further information is available under G1 – Political engagement and lobbying activities .

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All Metsä Board’s packaging materials, as well as its paperboards, mainly produced from renewable raw materials, can be recycled, depending on local recycling systems. The recyclability of Metsä Board’s paperboards has been tested in accordance with the Cepi method (Cepi Recyclability Laboratory Test Method Version 2; Fibre-based packaging recyclability evaluation protocol beta version). Except for the PE-coated grades, all the company’s paperboards are certified as industrially compostable in accordance with the DIN EN 13432 and/or ASTM D6400 standards, and as home compostable in accordance with the NF T 51–800 standard.

Product category rules (EPD International PCR) compliant with the ISO 14040 and ISO 14044 standards are used in the life cycle assessments of all the company’s products. The calculation model of the company’s life cycle assessments has been verified by an external partner, and selected products produced by the company have an environmental product decla- ration (EPD), stating the comparable results of the paperboard product’s life cycle assessment. With respect to Metsä Board’s field of business, product repairability or durability compared with the industry standard in practice is irrelevant to product use when accounting for resource outflows.

Waste and side streams

Continuous actions

Waste generated at Metsä Board’s production units include wood-based fractions, organic and inorganic sludge, ash, paper and paperboard waste, metals, and small amounts of plastic and glass waste, as well as energy waste from sorting at the mills. Examples of hazardous waste include oil and oily waste. Crushed concrete and metal waste are generated in construction and demolition.

Metsä Board’s key actions related to waste and side streams are the following:

Developing new purposes for production side streams jointly with partners to make wood use more resource-efficient and reduce the products’ environmental impact per product produced.

Most of the production side streams are utilised. Wood-based waste, sludge, ashes and lime are used in soil improvement and landscaping, fertilisers, chemicals industry applications, and in energy generation. Only a small share of production side streams are disposed of in landfills (exact figures can be found in the Waste use and disposal table). The utilisation of side streams often leads to additional expenses, but the decrease in landfill management fees also offers cost savings.

Some production units have their own waste management area, where operations are subject to an environmental permit. The environmental impacts of the mills’ own waste management areas are minimised in accordance with the environmental permits. Part of the waste is delivered to waste management companies whose operations are subject to envi- ronmental permits for processing or disposal. The sustainability of waste management operators is ensured in supply agreements.

The main process waste components are green liquor dregs generated in pulp production and ash, which is generated in energy production. As part of Metsä Group, Metsä Board is actively seeking industrial applications

for green liquor dregs by conducting its own research and pilot projects, and participating in universities’ jointly funded research projects.

Examples of side stream utilisation:

Jointly with Soilfood, Metsä Board is studying the utilisation of fibre-based side streams from paperboard mills in animal bedding. Cooperation with the Husum integrated mill began in 2025. New types of bedding fibres are a renewable alternative for peat, commonly used on animal farms.

Metsä Group’s innovation company Metsä Spring has invested in four start-up companies focusing on the further processing of the wood-based side streams of Metsä Group, including Metsä Board, and supports them in scaling up production and commercialising their products.

Metsä Group is committed to the national circular economy green deal. The participants set targets up to 2035 and commit to actions that promote a low-carbon circular economy.

In 2025, no significant capital or operating expenditure was allocated to key actions for resource use and the circular economy. In 2025, R&D expenditure was EUR 6.3 million.

Financial effects

The impacts, risks and opportunities concerning resource use and the circular economy identified in the material assessment are presented in the table on page 66 , and the time horizons used in their assessment are described on page 32 .

The main known or reasonably expected financial effects related to side streams concern emission rights and the use of wood-based energy, which are discussed under E1 – Climate change . A key uncertainty factor in the assessment of these impacts is the low predictability of EU legislation. Other potential additional costs are related to the increased utilisation of side streams, which, on the other hand, offers cost savings through reduced landfill management fees.

When developing new concepts promoting efficient resource use and the circular economy, their financial effects on the company’s business are continuously monitored through cost-benefit analyses and scenario analyses, combined with roadmaps using financial calculation methods. Strategic advantages and key financial figures are taken into account in the assessment of the investment proposals.

A more detailed discussion of potential future products for the packaging market and carbon capture as opportunities related to resource use and the circular economy can be found under E1 – Climate change .

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Report of the Board of Directors | Metsä Board Annual review 2025

Metrics

Inflows of material and energy streams

Wood-based raw materials, 1,000 t

2025

2024

Wood

3,902

4,292

Purchased pulp

293

345

Recycled fibre

0

The share of certified wood is disclosed under G1 − Business conduct.

Other raw materials, 1,000 t

2025

2024

Process chemicals

25

31

Coating, binders and pigments

247

279

Packaging materials

21

25

The sustainability of other raw materials is monitored using separate metrics. For exam- ple, the metric for raw material traceability tracks the proportion of recycled, reused and renewable materials of the total inflow of raw materials. This is described in greater detail under G1 – Business conduct .

The quantities of critical raw materials in Metsä Board’s production processes are limited. The company uses aluminium sulfate Al2 (SO 4 ) (H 2 O), as well as talc, which contains magnesium silicate, at some of its mills. Water use is discussed in more detail under E3 – Water resources . The use of tangible assets during the reporting year is described in the notes to the consolidated financial statements in section 4.2 Property, plant and equipment.

Share of renewable and recyclable raw materials and packaging materials*, %

2025

2024

Renewable materials

94

Recycled materials

0.1

0.2

*Share of the total weight of materials used in the reporting period.

Metsä Board uses recycled paperboard for the cores of paperboard reels.

Outflows of material and energy streams

Products, 1,000 t

2025

2024

Chemical pulp

550

619

BCTMP

398

504

Paperboard

1,331

1,539

Other bioproducts (tall oil and turpentine)

17

18

By-products, 1,000 t

2025

2024

Fertilising and soil improvement (lime, ash, sandy bark)

28

14

Industrial use (lime dust, ash, de-inking sludge)

30

18

Energy use (de-inking sludge, biopellet)

0

Total

58

32

Waste use and disposal, 1,000 t

On-site

Off-site

Total 2025

Total 2024

PROCESS WASTE (NON-HAZARDOUS WASTE)

Material utilisation

0

42

73

Energy use

49

0.3

49

55

Landfill

0

0.1

0.3

Total process waste

49

43

92

128

OTHER NON-HAZARDOUS WASTE

Material utilisation

0

6.8

4.1

Energy use

0

1.0

1.4

Landfill

0

0.1

0.04

Total other non-hazardous waste

0

7.8

7.9

5.5

HAZARDOUS WASTE

Material utilisation

-

0.3

Energy use

-

0.02

0.2

Incineration without energy benefit

-

0.1

0.07

Landfill

-

0.03

0.3

Other disposal*

-

0.1

0.2

Total hazardous waste**

-

0.6

1.1

Total waste

49

51

100

135

Share of landfill waste of total waste, %

0

0.5

0.2

0.5

* Disposal and treatment of waste other than landfilling. The amount also includes repackaging and pre-treatment prior to disposal operations.

** Metsä Board’s operations do not generate radioactive waste.

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Reporting principles for metrics

Resource inflows

Resource inflows are disclosed in the original state of materials. Wood volumes are disclosed based on the information received from Metsä Group’s Wood Supply and Forest Services business area, and disclosures of other raw materials are based on the received tonnes of raw material. The disclosed inflows of packag- ing materials are based on internal reporting.

The key assumptions made in resource inflow calculations are related to material conversion factors and the categorisation of materials into renewable materials and recycled materials. Some converted inflow amounts are based on assumptions regarding average conversion factors for specific materials or products. If a material cannot be categorised as renewable or recyclable with certainty, the assumption is that it is neither.

Resource outflows

The waste volumes include waste transferred directly from the mill process, interim storage, and construction and demolition projects external to mill functions, over which the company has operational control to final disposal, including material and energy recovery, landfill disposal, and hazardous waste treatment. Waste transferred from the mill process to interim storage is not included in the disclosed waste volumes. Moisture is included in the waste volume.

The volume of process waste delivered to landfills includes the volume of waste from production processes (in tonnes) delivered to landfills from all the production units. The 2030 sustainability target only applies to process waste. For example, it does not apply to waste generated in production units’ cafeterias, the volume of which is non-material compared with process waste.

The volume of waste treated in the mills’ own waste treatment areas is collected from weighting reports. Information about the volume of waste treated by external service suppliers and the treatment method is obtained from service suppliers.

It is impossible to classify material utilisation into subcategories in accordance with the standard, as the available information is based on waste legislation codes, which do not allow this distinction to be made. Estimating quantities is challenging because there are differences between code-specific waste data and the ESRS classification, which require further clarification to be reconciled. These additional clarifications are being made so that the classification can be assessed in the 2026 report.

The metrics have not been validated by an external party.

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Report of the Board of Directors | Metsä Board Annual review 2025

S – Social responsibility

S1 – Own workforce

Material impacts, risks and opportunities related to own workfor ce

Material sub-sub-topics

Impacts

Value chain stage

Time horizon

Risks and opportunities for Metsä Board

Value chain stage

Time horizon

Equal treatment and opportunities for all

Gender equality and equal pay for work of equal value

Diversity

Measures against violence and harassment in the workplace

Training and skills development

Wellbeing at work and the opportunities for continuous learning and career development improve alongside equality in the treatment, remuneration and recruitment of employees.

Opportunity: Strengthening of employer image and innovation, performance, and competitiveness as a result of selecting the most suitable talent for key positions

Wellbeing at work and opportunities for contin- uous learning and career development weaken if equality is not achieved in the treatment, remuneration and recruitment of employees.

Risk: A weaker employer image, innovation, performance and competitiveness if the most suitable talent is not recruited for key posi- tions, as well as a decline in Metsä Board's attractiveness, particularly among minorities

Working conditions

Social dialogue

Freedom of association, including the existence of work councils

Collective bargaining

Work-life balance

Employees’ work ability and wellbeing at work are improving as a result of actions that promote working conditions, such as company-specific collective agreements, flexible working hours and individual shift work models.

Opportunity: Increased work ability, job satisfaction and commit- ment to Metsä Board among the workforce, as well as an improved employer image and company performance

The quality of life and wellbeing of employees and their families deteriorates and inequality increases as a result of potentially inadequate working conditions.

Health and safety

Employees’ general physical and mental well- being and ability to work improve as a result of actions promoting health and safety.

Risk: Reduced work ability, job satisfaction and commitment to Metsä Board among the workforce, as well as a decline in employer image and company performance

Employees’ physical and mental wellbeing and work ability deteriorate as a result of potentially inadequate health and safety actions

Other work-related rights

Privacy

Inadequate data protection could jeopard- ise employees’ privacy and personal data protection, which causes mental strain and deterioration in wellbeing

Risk: Reduced work ability, job satisfaction, trust and commitment among the workforce, as well as permanent harm to Metsä Board’s reputation

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

Upstream value chain

Own operations

Downstream value chain

Short-term (less than one year)

Medium-term (1–5 years)

Long-term (more than 5 years)

Metsä Board’s 2030 sustainability targets

2030 target

2025

2024

2023

Total recordable incident frequency, own employees (TRIF)

0

4.8

3.4

6.1

Employee engagement, index (scale 0–100)

AAA

A

A+

The implementation of the measures defined based on the employee survey, %

100

-

Women in leadership roles, %

>35

25

23

Employee experience on diversity, equality and inclusion (DEI) implementation, Metsä for all -index (scale 0–100)

100

72

73

-

Anonymous recruitment for vacancies open to all, %

100

99.2

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Not all comparative data has been provided for all the new 2030 sustainability targets set in 2025.

Metsä Board’s 2030 sustainability targets are discussed in greater detail under Sustainability governance and strategy and Material sustainability-re- lated impacts, risks and opportunities.

The company’s own workforce has not directly participated in setting the targets, but the results of surveys focusing on the personnel, such as the Personnel survey, are considered in the materiality assessment.

The 2030 sustainability targets are discussed by the mills’ management teams, which include employee representatives, and in collaborative meetings with employee representatives. The results of progress towards sustainability targets are made available to all personnel on the internal intranet pages quarterly.

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Progress in targets

Total recordable incident frequency, own employees (TRIF) – The recordable incident frequency increased from the previous year but remained in line with the annual target of zero accidents by 2030. Unfortunately, one of the accidents was serious, so the company must continue to emphasise proactive safety work and the prevention of serious work-related accidents.

Employee engagement – The target was not achieved as planned. Actions to promote engagement – defined based on personnel surveys – were monitored and effectively implemented. The monitoring and implementation of actions will continue in the coming years.

Implementation of actions based on the personnel survey – Pro- gress towards the target was made according to plan, and the 100% target was achieved in 2025. The actions focused on areas such as leadership development, strengthening a culture of open discussion, and improving safety management.

Women in leadership roles – The proportion of women in leadership roles did not meet the 2025 target, as the figure remained unchanged from the previous years. The metric and results from previous years were updated in 2025.

Employee experience on diversity, equality and inclusion (DEI) implementation – Progress towards the target was not as planned. However, the Metsä for All vision was promoted by training supervisors in diversity, equality and inclusion. In addition, employees at production units were trained about the importance of psychological safety in the workplace community. Employee awareness and competence will continue to be developed through internal training in the coming years, and the mandatory e-learning course on equality for all employees will be updated in 2026.

Anonymous recruitment for vacancies open to all – The use of anonymous recruitment became established, and the 100% target was achieved. This supports Metsä Board’s goal of promoting equality in recruitment processes and reducing the impact of preconceptions in recruitment decisions.

Affected own workforce

Most of the employees belonging to the company’s own workforce are in an employment relationship with the company. A relatively small share of employees of third-party companies, who have an agreement on the supply of labour with Metsä Board, work in ICT services and at production units, for example.

The identified material negative impacts are mainly related to individual cases. Those highlighted in the human rights impact assessment include impacts on safety at work and factors straining wellbeing. Workers at production units and in investment projects face a higher risk of accidents. The most typical accidents consist of injuries to hands and feet. Moreover, all employees may be exposed to negative impacts related to mental wellbeing and/or loading.

Metsä Board has also identified potential negative impacts on diversity and the achievement of equality, including challenges to gender equality in a male-dominated industry. Challenges may also arise in the achievement of diversity regarding the origin, language or age of the company’s own workforce, and the equal treatment of minorities.

In addition to the most significant impacts, the assessment identified potential negative impacts related to working conditions, particularly

concerning the uneven distribution of work and work-life balance. Potential negative impacts on employee privacy have also been identified in data protection and information security.

Policies

The sustainability of Metsä Board’s own workforce is guided by applicable legislation, as well as policies comprising Metsä Group’s Code of Conduct and others approved by the company’s Board of Directors, the Metsä for All vision and management systems. The policies apply to all Metsä Board’s own employees. The key occupational safety training applies to the company’s own workforce, meaning its employees and leased labour. The Code of Conduct and policies are discussed in more detail under G1 – Business conduct .

The Motivated people strategic programme focuses on the competence development of management and employees; the mills’ common operating model; a diverse, equal and inclusive (DEI) culture; the implementation and development of an ethical and respectful corporate culture; and ensuring future employee needs. The goal is that everyone in the workplace community understands the significance of their role and work in strategy implementation. The Safe and Efficient Operations and Organic Growth strategic programme focuses on topics such as the continuous improve- ment of occupational safety. One of the goals is to reduce the number of work-related accidents.

Equal treatment and opportunities for all

Metsä Board is committed to promoting the diversity, equality and inclu- sion (DEI) of its own workforce. This work is guided by Metsä Group’s Code of Conduct, Equality Policy and the Metsä for All vision. The HR function guides and carries out DEI work in cooperation with other functions.

The Code of Conduct and Equality Policy include the prohibition of all discrimination based on gender, age, origin, race, nationality, language, religion, belief, opinion, political activity, trade union activity, family relations, pregnancy, health, disability, sexual orientation or any other personal characteristics. Indirect discrimination is also prohibited. The non-discrimination principle applies throughout an employment relation- ship, regardless of whether the employment relationship is permanent, temporary or part-time.

Awareness of diversity, equality, inclusion and non-discrimination is pro- moted through the Code of Conduct e-learning course and DEI e-learning course, which are mandatory for employees, as well as through mental safety training given by internal coaches. The themes are part of the induction of new white collars and apprentices, as well as the company’s management and leadership coaching.

Training and skills development

Metsä Board’s management and employees’ skills development are guided by the Human Resources Policy. Metsä Board’s management and HR function are in charge of implementing the policies included in the Human Resources Policy. Management and supervisory work is supported through coaching, where participants discuss matters such as Metsä Group’s good leadership principles. Employees’ skills are developed in the long term in line with Metsä Board’s strategy and goals.

Working conditions

Metsä Board complies with the applicable practices for working conditions in its operating countries, in addition to local legislation. In its Code of

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Report of the Board of Directors | Metsä Board Annual review 2025

Conduct, the company is committed to fair terms and conditions of employment. 76% (77) of Metsä Board’s employees are covered by collective agreements. In Finland, Metsä Board follows company-specific collective agreements for the chemical forest industry.

All Metsä Board production units and 88% (88) of the employees are located in Finland and Sweden, both of which have high-standard statutory requirements concerning working conditions such as reasonable working time, annual leave, parental leave and part-time work. The wage payment practices for the family-related leave of employees in Finland have been harmonised to a level that exceeds the statutory requirements concerning family-related leave and offers parents equal opportunities to take care of their child. All Metsä Board employees are paid adequate wages (as was the situation at the end of the reporting period, 31 December 2025). Metsä Board’s employees have the right to choose whether they belong to a trade union or not.

Health and safety

Metsä Board’s occupational safety is guided by the safety management system, comprising the Corporate Security Policy and the safety princi- ples, standards, processes and work instructions. Metsä Board’s safety management system considers each country’s legislation – for example, the Occupational Safety and Health Act in Finland. The Corporate Security Policy defines the goals and operating models of security operations, to which all employees must commit in their activities. The safety principles guide safety-related decisions and define the criteria for preparing safety processes and standards. In addition to guiding occupational safety, the ISO 45001 standard calls for a safety management system. The imple- mentation of safety policies is the responsibility of Metsä Board’s CEO in accordance with the requirements specified by Metsä Group’s senior management. The roles and responsibilities of occupational safety are defined in the Safety principles. The related e-learning course is mandatory for the employees of production units.

All Metsä Board mills comply with the ISO 45001 standard for occupa- tional health and safety. All Metsä Board mills apply the 5S method for organising workplaces and standardising working methods, which aims to increase productivity, safety and wellbeing at work.

100% (100) of the production units’ employees and service providers come under the scope of the occupational safety management system, which has been certified by a third party. Employees working at production units account for 81% (81) of Metsä Board’s total workforce. Office employees outside production units come under the scope of Metsä Board’s occupational safety management system, but these operations do not have third-party certification.

At Metsä Board, wellbeing and the improvement and maintenance of work ability are guided by the Code of Conduct and the Occupational Safety and Wellbeing instructions, in which Metsä Group commits to promoting employees’ physical and mental wellbeing. The promotion of workplace wellbeing and work ability is proactive, the goal being to identify threats to employees’ work ability, initiate actions and maintain the employees’ health throughout their careers. The sites are responsible for compliance with applicable legislation and Metsä Group’s requirements for workplace wellbeing.

Metsä Board organises healthcare for its employees in accordance with each country’s legislation. Information about healthcare services is availa- ble on the company’s intranet pages, and it is also included in employees’ induction.

Other work-related rights

As part of the Code of Conduct, Metsä Board is committed to acting in accordance with the United Nations (UN) Guiding Principles on Business and Human Rights and to respecting internationally recognised human rights in accordance with the UN’s Universal Declaration of Human Rights and the ILO’s Declaration on Fundamental Principles and Rights at Work. The company is committed to remedying any negative impacts on human rights in accordance with the UN Guiding Principles on Business and Human Rights, and Metsä Group’s Principles on non-compliance notifica- tions and the related investigation. In the Code of Conduct, Metsä Board is committed to ensuring that no child or forced labour, human trafficking, or other forms of modern slavery occurs in its business operations and supply chain. Metsä Board has focused its production in countries with no significant risk of child or forced labour. Metsä Group publishes a transpar- ency statement annually in accordance with the UK Modern Slavery Act, in which it describes the actions taken to ensure that no modern slavery occurs in the company’s own operations or its supply chain. Metsä Board supports the UN Global Compact initiative and its principles on human rights and employees, among other things. Human rights matters are discussed in e-learning courses such as those focusing on sustainability, the Code of Conduct and equality. All employees are required to regularly complete the courses.

Privacy

As part of its Data Protection Policy, Metsä Board is committed to protect- ing the privacy of people. The Data Protection Policy defines the principles and rules that must be followed when processing personal data. Personal data related to the employees’ health are processed only by designated individuals in accordance with data protection legislation and in situations in which the data is required by law. Employees’ health-related data is stored separately from the employees’ general personal data. The data protection management model helps ensure compliance with legislation, including the EU’s General Data Protection Regulation (GDPR).

Engaging with own workers and workers’ representatives about impacts

Metsä for All vision

Interaction with employees played an important role when defining the Metsä for All vision. The vision’s content was influenced by the opinions of the international working group comprising the company’s employees, as well as the results of a survey for all employees. The site-specific develop- ment measures related to the vision’s implementation were determined in workshops for local management, aided by site-specific DEI employee surveys.

Statutory equality and non-discrimination plans are drawn up annually with employee representatives.

Collective agreements

Company-specific collective agreements for the chemical forest industry are renewed among the parties based on the principle of continuous negotiations. The drafting of company-specific collective agreements marked the beginning of measures carried out jointly with the employee representatives to renew and improve work life.

73

Cooperative activities

Metsä Board complies with local legislation and applicable collective agree- ments in all its operating countries. Cooperation is carried out in accord- ance with each country’s legislation. The aim of cooperation is to develop the company’s operations and improve the employees’ opportunities to influence their own work, working conditions and decision-making related to their position in the company. HR, management and employee repre- sentatives are jointly in charge of the measures related to cooperation.

In Finland, elected representatives participate annually in Metsä Group’s cooperation forum and Metsä Board’s corporate meeting, where the elected representatives and the company management discuss the elected representatives’ questions, development proposals and the group’s financial position. In addition, the management team at all mills in Finland includes an elected representative.

Metsä Board has a European Works Council (EWC). The goal of the EWC is to promote the company’s internal information flow and contacts between the Corporate Leadership Team and employees, as well as to regularly discuss questions about the company’s multinational operations that are significant to the employees, primarily in accordance with the Finnish version of the EWC agreement. The Works Council is not intended for discussing matters regulated through national or local collective agreements.

Personnel survey and Pulse survey

The company annually conducts a Personnel survey measuring employee engagement, the quality of leadership and employees’ views on business ethics. In addition, the survey provides an index measuring employee engagement and a Metsä for All index, which measures employees’ experi- ences of diversity, equality and inclusion in the company. The results of the Personnel survey are supplemented by the Pulse survey, conducted four times a year, which measures employee commitment in the company and employees’ views on the ethics of business. Through the Personnel survey and the Pulse survey, employees can give written feedback on the practical implementation of ethics and report any grievances. The Compliance and Ethics Channel, intended for reporting ethical grievances, is discussed in greater detail under G1 – Business conduct .

The HR function is responsible for both the Personnel survey and the Pulse survey, and supports the company management in handling the survey results and addressing them in decision-making. The results are discussed at different organisational levels and with elected represent- atives. Further information about work on the actions is provided under Actions . The results of the Personnel survey and Pulse survey are used as indicators for strategy implementation.

The effectiveness of the Personnel survey and the Pulse survey is measured by evaluating the response rates and the implementation of the defined development measures, and by comparing the results with those of other companies.

Safety talks and occupational health and safety committees

Occupational safety is promoted and supported with safety talks, or information sessions for the workforce, which are recorded in the system. The scope of safety walks is assessed by monitoring the target amounts set for them.

The occupational health and safety committees of mill sites regularly discuss the promotion of occupational safety with various groups of the workforce. The occupational health and safety committee prepares an annual action plan for occupational safety, based on which the occupa- tional health and safety manager and the committee jointly determine the key development measures related to occupational safety. The occupational health and safety committees represent the company’s own workforce as a whole – that is, the company’s own employees and leased labour.

The line management is responsible for the implementation of safety walks and for occupational health and safety committees. To increase the effectiveness of communication, stakeholders have been involved in the occupational safety communication processes.

Processes to remediate negative impacts and channels for own workers to raise concerns

Metsä Board considers its obligation to remediate any negative impacts on its own workforce. In accordance with Metsä Group’s Principles on non-compliance notifications and the related investigation, the company conducts a case-by-case assessment of reasonable remedies to ensure that the injured party is put in the same position as they would have been in had the incident of non-compliance not occurred, or as close as possible to it. The rights of the injured parties are taken into account in the assessment.

Compliance and Ethics Channel

The company’s own workforce can report any ethical concerns or non-compliance with legislation they detect through Metsä Group’s Compliance and Ethics Channel or to their supervisor, local management, HR or the Compliance Committee. The Compliance and Ethics Channel, raising concerns and the processing of reported concerns are discussed in greater detail under G1 – Business conduct .

Working conditions

Health and safety

Metsä Board’s risk assessment and management is supported by the HSEQ system, designed for recording and monitoring safety observations, accidents, close calls, corrective actions, safety talks and safety walks. Entries can be made by anyone belonging to the company’s own workforce. Safety observations are discussed at daily meetings. Metsä Board does not accept countermeasures against whistle-blowers. If required, whistleblowers may also choose to submit a report anonymously through the Compliance and Ethics Channel.

All accidents and hazardous situations are investigated. The investiga- tion creates conditions for avoiding similar situations and identifying any shortcomings in safety management. When the investigation report is completed, a summary of the investigation is distributed to all Metsä Group business areas.

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Report of the Board of Directors | Metsä Board Annual review 2025

Actions

As part of its cost savings and profit improvement programme, Metsä Board initiated change negotiations covering the entire personnel in October 2025. As a result of the negotiations, 310 jobs were cut in all Metsä Board’s countries of operation in total. Earlier in the year, the closure of the Tako paperboard mill and the improved efficiency of the Kyro paperboard mill led to a reduction of 208 jobs, of which 95 people were re-employed within Metsä Board and Metsä Group.

Metsä Board surveys the measures targeted at its own workforce based on the identified impacts. Impacts on the company’s own workforce are systematically assessed in the double materiality assessment, in which attention is paid to the results of surveys focusing on the employees such as the annual Personnel survey.

Based on the results of the Personnel survey, an action plan is drawn up for the areas with the weakest results. Supervisors discuss the results of the Personnel survey with their own teams. The discussion can also involve the HR function and a third party if required. Based on the results, the teams choose the required measures, and their implementation is monitored at team meetings and by the company management.

The effectiveness of the implemented actions is assessed with the Per- sonnel survey and the Pulse survey. The surveys measure the realisation of ethical and equal operations, employee engagement, and the quality of leadership. Based on the reports made through the Compliance and Ethics Channel, and other cases submitted for investigation to the Compliance Committee, an idea of the realisation of ethical operations at an annual level can be formed.

Equal treatment and opportunities for all

Continuous actions

The focal points of the Metsä for All vision are equality and gender equality, diversity, inclusion, and cultural change. They guide the development of employee processes and the annually determined measures for achieving the vision.

As part of the continuous development work, an equal pay survey is con- ducted annually, employees are trained regularly, and measures are taken to ensure that the gender distribution in leadership training corresponds to the DEI targets. In successor planning, attention is paid to the goal of a more balanced gender distribution in company positions. Metsä Board’s recruitment partners are committed to DEI targets.

Anonymous recruitment is the main recruitment method. It supports employee diversity by encouraging people with different backgrounds to apply for jobs at Metsä Board. Anonymous recruitment minimizes the risk of bias and its potential impact on recruitment. After the introduction of anonymous recruitment, the share of women of all recruited employees has increased by 8% (21) in relative terms between 2021 and 2025.

Actions taken during the reporting year

During 2025, a training programme focusing on themes of psychological safety and their internal coaching was implemented for occupational safety and health committees in Finland, and corresponding target groups in other countries of operation. The programme covered topics such as inappropriate treatment, bullying, harassment, discrimination and psychological safety, as well as ways to address grievances. Participants in the training went on to train the members of their own unit’s occupational

safety and health committee and supervisors in the topics covered by the training. In addition, Metsä Group’s HR function organised a training programme on diversity to support professional competence.

Training in psychological safety and inclusion will continue at production units in the coming years, and similar training is also being planned for personnel working outside production units.

Training and skills development

Continuous actions

The aim is to ensure the availability and retention of skilled employees by investing in the development programmes, successor planning, coop- eration with educational institutions, and employer image. Competence surveys support the development of multiple skills and competence meas- urement. Personal assessments and wider competence surveys can guide the development of individual, group and organisational-level competence, and the content of development programmes.

Metsä Board encourages its employees to actively develop their com- petence and participate in different types of training. Everyone is provided with a personal development plan to support their development at both the personal and team levels. Mentoring programmes and job rotation support the employees’ professional growth and enable the use of tacit knowledge.

Competence development is monitored at two levels. Metsä Board monitors the number of personal development plans and Personnel survey results related to the opportunities to use one’s own competence. In addi- tion, feedback is collected on academies and other training programmes.

Metsä Board’s employees have a bonus scheme, and the personal performance bonus targets of each employee include a sustainability target. Personal goals and areas of development are set annually, and their progress is monitored in performance and development appraisals (PDAs), which all employees conduct with their supervisor twice a year. The bonus scheme does not cover trainees, thesis workers, employees who have worked less than four months during the bonus scheme year or individuals who are not in an employment relationship at the time of the bonus payment.

Actions taken during the reporting year

In 2025, competence was developed in the academies for finance, sales, procurement, sustainability and leadership. In addition, a production academy was launched.

The Learning functionality was introduced to the Workday HR system to support the monitoring of skills development and make it more efficient, as well as to facilitate training management. This functionality presents all the training courses offered by Metsä Group in one place and guides systematic competence development at the individual level.

Working conditions

All Metsä Board’s employees are included in the same HR system, which reduces the risk of employment conditions or wages being in breach of the law or agreements. In some positions, employees have flexible working hours and a hybrid working model, which enables them to work remotely part of the week. The company supports the employees’ wellbeing at dif- ferent stages of life and enables a long career by offering various solutions such as job rotation.

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Actions taken during the reporting year

The change negotiations carried out during the reporting year resulting in the offering of change security to the affected employees in accordance with local legislation in each country.

Health and safety

Continuous actions

In Metsä Board, safety management is based on the prevention of hazards and risks. Operations are guided by safety processes and standards and work instructions. The e-learning course in the principles of safety management is mandatory for the production units’ employees. The general safety induction e-learning course dealing with hazards and risks is mandatory for the company’s own workforce working at Metsä Board’s production units and construction sites.

A safe environment is ensured with common safety-at-work standards, continuous proactive measures – such as risk assessments, safety obser- vations, safety walks and safety training – and investments improving safety. Safety standards define separate procedural requirements for high- risk work tasks. The permit to work standard covers the most important of these: lockout/tagout, working at heights, lifting work, work in confined spaces, excavations and hot work.

The zero accidents target is supported by long-term focal areas for safety – the deployment of common safety-at-work standards, personal risk assessments and the development of hand safety. The measures determined based on the focal areas guide the development of safety work, define the key targets and make safety work more predictable.

Occupational safety actions are actively monitored in the HSEQ system, in which the actions are categorised based on their impact on occupational safety. The zero accidents target is used to assess the effectiveness of occupational safety actions in the big picture.

Using health checks and health surveys, occupational healthcare evaluates employees’ health in view of the demands of their duties and the exposures related to their work. The healthcare services of leased labour are handled by their own employer. Workplace conditions are made as health-secure as possible – for example, in terms of tidiness and adequate ventilation. The appropriateness and adequacy of personal protective equipment is also ensured. The most common occupational illnesses – allergic skin or respiratory reactions caused by dust or chemicals – are becoming less common. Metsä Board has not been made aware of any fatalities from occupational diseases among its own or its contractors’ workforce.

To support work performance, operating models have been defined for rehabilitative activities and early support. A substance abuse programme is also in place. The implementation of early support is monitored in relation to the defined targets and needs. Supervisors are offered regular annual guidance and training in managing wellbeing at work to ensure that work ability and wellbeing at work are seen as part of day-to-day management.

Actions taken during the reporting year

In 2025, the key focus areas for safety work were a Group-wide safety management training programme and the establishment of the Fair & Just safety culture.

The training programme on safety management continued in 2025 at Finnish production units using the “train the trainer” model, in which supervisors trained production employees. The training focused on safety responsibilities and obligations at the various levels of the organisation. In addition, the training for white collars and managers, launched last year, was expanded in 2025 to include safety training for production personnel at the Husum paperboard and pulp mill.

The principles of the Fair & Just safety culture were introduced as part of safety training. The purpose of the new approach is to emphasise how important compliance with instructions is for accident prevention and the responsibility of supervisors for ensuring that the working practices of their team members are safe. The implementation method focuses on raising employee awareness of key safety rules and ensuring commitment to acting in accordance with them. In addition, the approach harmonises practices for addressing deviations and follow-up measures concerning the individual, their supervisor, and the entire organisation.

In 2025, the focus in promoting wellbeing at work was on the employees’ musculoskeletal condition and support for mental wellbeing. The main themes of the webinars and info session on health topics aimed at employ- ees were ergonomics, including cognitive ergonomics, and strengthening resilience and psychological safety.

The trial of an individual working time model for shift work, which was ini- tiated in 2024, continued at all production units in Finland. The experiences were positive, and the trial will be continued in 2026.

As a result of the change negotiations conducted during the reporting year, support was offered to employees and supervisors for dealing with challenging situations and redundancies.

Other work-related rights

Continuous actions

The implementation of human rights is considered as part of the develop- ment of HR processes. In addition to the human rights impact assessment conducted in 2024, the Compliance and Ethics Channel, the ethics-related questions in the revised Personnel survey, and the collected open-ended feedback are important tools in identifying human rights impacts.

Actions taken during the reporting year

Investments in occupational safety and wellbeing, DEI work, and e-learning courses dealing with these topics were key practical measures affecting the implementation of human rights in 2025.

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Privacy

Continuous actions

Regarding data protection, procedures for processing employees’ personal information have been defined, and all employees are required to comply with the Data Protection Policy in place. At Metsä Board, data protection and information security are implemented through high-quality technical and organisational actions. The same requirements apply to companies providing occupational health services, and these requirements are included in the agreements. To ensure data protection, employees take e-learning courses such as the data protection course, mandatory for all employees. In addition, a mandatory advanced e-learning course is provided for HR personnel and supervisors, focusing specifically on the processing of employees’ data and related special legislation. Data protection themes are discussed in meetings organised with heads of HR and the owners of key HR processes four times a year. Moreover, everyone has the right to submit requests concerning their personal data through Metsä Group’s website.

Actions taken during the reporting year

In 2025, an updated version of the advanced e-learning course on data protection for all supervisors and HR personnel was published.

Financial resources allocated to the management of material impacts

In 2025, voluntary social costs totalled EUR 4.9 (4.6) million. These included the costs of occupational health services, recreational activities, occupational safety equipment and lunch.

In 2025, the employees’ training expenses totalled EUR 2.1 (1.5) million.

Incidents, complaints and severe human rights impacts

In 2025, Metsä Board was made aware of incidents that might have had a direct or indirect adverse impact on the company’s human rights obliga- tions. Metsä Board is making progress towards its goal of zero accidents as planned. Despite a strong focus on safety, two serious workplace accidents occurred in 2025. One of the incidents involved a service provider and one involved the company’s own employee. All accidents were thoroughly investigated in close cooperation with the persons involved and specialists. As part of the incident investigations, corrective and preventive actions were determined for the cases. In addition, lessons learned from the incidents were shared with other business areas to prevent the recurrence of similar accidents.

In 2025, the company received three reports of harassment or discrim- ination. One of the investigated harassment cases resulted in termination of employment, and one led to a written warning. None of the reports of misconduct brought to the company’s attention concerned forced labour or the use of child labour.

The mechanisms for identifying, reporting and investigating grievances are discussed under G1 – Business conduct .

Metrics

Employee head count by gender

2025

2024

Male

1,650

1,856

Female

480

553

Other

0

Not reported

0

Total employees

2,130

2,409

In Metsä Board’s personnel system, a person’s gender is determined based on their legal gender.

Employee head count by country

2025

2024

Finland

1,131

1,344

Sweden

740

775

Poland

116

127

United States of America

62

76

Other countries

81

87

Countries with more than 50 employees.

Employee turnover and recruitment

2025

2024

Employee turnover rate, total

253

106

Employee turnover rate, %

13

4.8

Female

13

5.3

Male

13

4.7

Under 30 years old

16

3.4

30-50 years old

10

2.8

Over 50 years old

15

7.1

Number of new hires, total

30

62

Female

9

18

Male

21

44

Under 30 years old

6

20

30-50 years old

21

33

Over 50 years old

3

9

77

Employees by contract type, broken down by gende r

Female

Male

Other

Not reported

Total

2025

2024

2025

2024

2025

2024

2025

2024

2025

2024

Number of employees

480

553

1,650

1,856

0

2,130

2,409

Number of permanent employees

439

480

1,550

1,741

0

1,989

2,221

Number of temporary employees

37

65

82

89

0

119

154

Number of non-guaranteed hours employees

4

8

18

26

0

22

34

Number of full-time employees

455

518

1,589

1,765

0

2,044

2,283

Number of part-time employees

25

35

61

91

0

86

126

In Metsä Board’s personnel system, a person’s gender is determined based on their legal gender.

Employees by contract type, broken down by country

Finland

Sweden

Poland

United States of America

Others

Total

2025

2024

2025

2024

2025

2024

2025

2024

2025

2024

2025

2024

Number of employees

1,131

1,344

740

775

116

127

62

76

81

87

2,130

2,409

Number of permanent employees

1,021

1,192

719

756

106

111

62

76

81

86

1,989

2,221

Number of temporary employees

88

118

21

19

10

16

0

1

119

154

Number of non-guaranteed hours employees

22

34

0

22

34

Number of full-time employees

1,089

1,268

701

729

114

126

61

75

79

85

2,044

2,283

Number of part-time employees

42

76

39

46

2

1

2

86

126

Countries with more than 50 employees.

Collective bargaining coverage and social dialogue

Collective Bargaining Coverage

Social dialogue

Coverage rate

Employees - EEA

Employees - Non-EEA

Workplace representation (EEA only)

0-19%

Poland

United States of America

20-39%

40-59%

60-79%

Finland

80-100%

Sweden

Finland, Sweden

Countries with more than 50 employees.

Non-employees in own workforce

2025

2024

Total number of non-employee workers in the com- pany's own workforce

2

3

Distribution of employees by age group

2025

2024

Under 30 years old

223

330

30-50 years old

998

1,095

Over 50 years old

909

984

Gender distribution at top management level

2025

2024

Share of men and women in top management

115/39

130/43

Share of men and women in top management, %

75/25

Social protection

Countries that do not have social protection for the listed major life events

Sickness

Unemployment starting from when the own worker is working for the company

India, Singapore

Employment injury and acquired disability

India, Singapore

Parental leave

Retirement

India

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Report of the Board of Directors | Metsä Board Annual review 2025

Training and skills development

2025

2024

Employees that participated in regular performance and career development reviews, %

96

94

Women

94

88

Men

97

96

Blue collar

96

94

White collar

98

94

Executive

96

97

Average number of training hour per person for employees

11

20

Women

11

23

Men

10

19

Blue collar

9.3

18

White collar

12

24

Executive

20

34

Family-related leave

2025

2024

Number of employees entitled to take family-related leave

2,130

2,409

Number of employees that took family-related leave

201

Number of women that took family-related leave

49

46

Number of men that took family-related leave

152

155

Employees entitled to take family-related leave, %

100

Employees that took family-related leave, %

9.4

8.3

Women that took family-related leave, %

10

8.3

Men that took family-related leave, %

9.2

8.4

Health and safety

2025

2024

OWN EMPLOYEES

Occupational accidents

17

13

Total recordable incident frequency, TRIF

4.8

3.4

Lost time occupational accidents

15

11

Lost time accident frequency, LTA1F

4.2

2.9

Fatal occupational accidents

0

Occupational diseases

0

Fatal occupational diseases

0

Days lost to work-related injuries and fatalities from work-related accidents, work-related ill health and fatalities from ill health

195

265

SERVICE PROVIDERS

Occupational accidents

10

4

Total recordable incident frequency, TRIF

5.2

2.0

Fatal occupational accidents

0

Total remuneration

2025

2024

The annual total remuneration ratio of the highest paid individual to the median employee annual total remuneration (excluding the highest-paid individual)

16

25

Total remuneration ratio of women and men

Finland

Sweden

Poland

United States of America

%

2025

2024

2023

2025

2024

2023

2025

2024

2023

2025

2024

2023

Blue collar

92

94

95

100

97

-

White collar

98

96

98

99.5

97

93

98.6

97

98

95

97

-

Countries with more than 50 employees

Incidents, complaints and severe human rights impacts

2025

2024

ALL REPORTED INCIDENTS RELATED TO UNETHICAL BEHAVIOUR

All reported cases

29

22

Reported cases which led to full-scale investigation

14

13

Number of complaints filed to National Contact Points of OECD Multinational Enterprises

0

DISCRIMINATION AND HARASSMENT INCIDENTES

Reported cases related to discrimination and harassment

3

Confirmed cases of discrimination and harassment

2

Total amount of fines, penalties, and compensation paid for the reported cases of discrimination and harassment

0

SEVERE HUMAN RIGHTS INCIDENTS

Severe human rights incidents (child labour, forced labour, human trafficking)

0

Total amount of fines, penalties, and compensation paid for the severe human rights incidents

0

Reporting principles for metrics

The figures for the company’s own workforce include the entire Metsä Board Group. The number of employees used in the calculations is indicated as the number at the end of the reporting period (31 December 2025). The number of employees also includes non-active employees such as employees on family-re- lated leave. Metsä Board annually employs around 250 (330) seasonal summer employees, thesis workers and trainees, some of whom are not employed at the end of the reporting period, when the number of employees is determined. The number of employees as full-time equivalents, at the end of the year and on average is presented in the Consolidated Financial Statements, Notes 2.1. The most significant factor explaining the decrease in personnel numbers compared with the previous year is the change negotiations conducted in 2025.

The metrics have not been validated by an external party.

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Employee turnover and recruitment

Recruitment includes permanent new hires. Employee turnover includes all leavers, whatever the reason (excluding transfer of business), divided by the number of employees. The figure includes permanent employment relationships.

The share of anonymous recruitment vacancies open to all includes the recruitment carried out in the Workday system. Workday is used in most recruitment. For example, cases in which the job applicant directly contacts the production unit are not included in the calculation.

Non-employees in own workforce

Non-employee workers in the company’s own workforce include workers who have concluded an agreement on the supply of labour with Metsä Board – that is, self-employed people and workers provided by companies that primarily engage in employ- ment services. No significant changes usually take place in the number of workers over the year.

Collective bargaining coverage and social dialogue

There have been no changes in the listed countries or coverage rates compared to the baseline year 2024.

Diversity metrics

The scope of the gender distribution of management and the scope of Metsä Board’s “Women in leadership roles” metrics were updated in 2025. A requirement level has been defined for man- agement tasks covered by the metrics, and these requirements are met by demanding management and specialist roles. These include all CEO, SVP and VP roles, and some other demanding roles below that level. In connection with the update, the figures for the reference years have been updated in accordance with the new definitions.

Social protection

The lack of social security for the listed life events applies to all employee groups, a total of 10 (13) people in the listed countries. There have been no changes in the listed countries compared to the baseline year 2024.

Health and safety

An occupational accident is reported if a person injured at work requires medical treatment or adapted or replacement work, or if the accident leads to their absence. In the calculation of lost-time accidents and LTA1F rate, only accidents that have led to at least one day of absence are taken into account. The assessment of a serious occupational accident is based on the definition provided by the Occupational Safety and Health Administration in Finland’s Tyosuojelu.fi website.

Frequencies of work-related accidents have been calculated per million hours worked. The working hours of service providers have been estimated based on procurement costs. The number of work-related accidents is indicated separately for the compa- ny’s own employees and service providers.

The disclosed days absent may involve uncertainty due to changes made afterwards. Days absent due to occupational diseases also include absences due to occupational disease examinations. In the case of fatal occupational accidents, the number of days absent is indicated as 0 for calculation reasons. There were no fatal occupational accidents in 2025 or 2024.

Family-related leave

Family-related leave includes maternity leave, paternity leave and parental leave available under national legislation and collective agreements.

Compensation metrics

The total pay ratio of women to men has been calculated as an average of women and men in the same pay category, weighted by the number of employees. If pay categories are not used in the unit, pay has been compared within the same site. The calculations are based on the gross hourly wage of employees and the gross annual salary of white collars maintained in the HR management system. The calculation methods are developed to take the requirements of the Pay Transparency Directive into account.

The adequate wages indicator is calculated by comparing employees’ total remuneration with available comparative data. The comparison is based on the national minimum wages confirmed in accordance with the EU Minimum Wage Directive (2022/2041). In countries without a national minimum wage, such as Finland and Sweden, the comparison has been made using regional market data provided by an external partner.

Incidents, complaints and severe human rights impacts

Cases concerning the company’s own workforce that may have involved a direct or indirect negative human rights impact have come to the company’s attention through either the Compliance and Ethics Channel or a notification made to a member of the Compliance Committee. The figures also include cases involving a potential human rights impact that exceed the materiality threshold based on the Compliance Committee’s evaluation.

Personnel survey

The Personnel survey results are based on the annual employee survey. All Metsä Board employees can respond to the survey. Responses are collected on a scale of 1−4 (fully disagree/agree), and an external service provider converts the responses to indexes on a scale of 0−100 (100 = everyone fully agrees).

The results of the Metsä for All index are based on five questions in the Personnel survey of employee experience of diversity, equality and inclusion (DEI) implementation.

The index depicting employee engagement is based on the results of the Personnel survey’s statements concerning the employee’s own work, team, leadership and company, for which benchmark data is available. The results are compared with European benchmarks, and the level of employee commitment is derived from this. The AAA target is “very good” compared with the benchmark, and the threshold value for achieving it in the personnel survey is 81.3 in relation to the European benchmark.

Group and business level measures based on the Personnel survey are implemented. The measures are recorded in a system that also tracks their implementation status.

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S2 – Workers in the value chain

Material impacts, risks and opportunities related to workers in the value chain

Material sub-sub-topic

Impacts

Value chain stage

Time horizon

Risks and opportunities for Metsä Board

Value chain stage

Time horizon

Working conditions

Secure employment

Working time

Adequate wages

Metsä Board’s requirements and control mechanisms such as the model for combating the grey economy may have a positive impact on the working conditions of suppliers’ employees

Opportunity: Increased work ability, wellbeing and commitment among suppliers’ employees, as well as a stronger reputation for the company as a responsible and safe partner

The wellbeing of suppliers’ and customers’ employees may be adversely affected by poor working conditions, potentially widening inequality and impacting their families’ quality of life

Health and safety

Metsä Board’s safety requirements can positively influence the wellbeing and work ability of suppliers’ employees, and the wellbeing of the employees’ families

Risk: Decline in the work ability, job satisfaction, and commitment of suppliers’ and customers’ employees, and contractors, and damage to the company's reputation as a responsible and safe partner

The work ability and overall wellbeing of suppliers’ and custom- ers' employees may be compromised, and occupational acci- dents increase, due to insufficient health and safety standards or a lack of effective enforcement

Other work-related rights

Child labour

Forced labour

A potential infringement of labour rights in Metsä Board’s value chain could lead to adverse human rights impacts, reduced quality of life for suppliers’ and customers’ employees and their families, and widening social inequality

Risk: Metsä Board’s reputation as a responsible partner and operator at risk

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

Upstream value chain

Own operations

Downstream value chain

Short-term (less than one year)

Medium-term (1–5 years)

Long-term (more than 5 years)

Metsä Board’s 2030 sustainability target

2030 target

2025

2024

2023

Total recordable incident frequency, contractor employees (TRIF)

0

5.2

2.0

1.7

Metsä Board has set sustainability targets in addition to the “Zero acci- dents” target concerning value chain workers and supplier commitment in the Code of Conduct, as well as supplier assessments and audits. These targets are discussed under G1 – Business conduct .

Progress in targets

Total recordable incident frequency, contractor employees (TRIF) – Unfortunately, the recordable incident frequency did not progress towards the target of zero accidents as planned, and there was also one serious injury among the incidents. Metsä Board’s target is to achieve even stronger results in this cooperation sector in the future.

Affected workers in the value chain

Workers in the value chain who may be affected by impacts work on Metsä Board’s own sites, and the upstream and downstream value chain. Depending on their nature and the stage of the value chain, actual impacts may be individual incidents such as occupational accidents or be systemic, especially in long value chains and high-risk countries.

Value chain workers are involved in Metsä Board’s investment projects, production unit maintenance, and harvesting and transport. Metsä Group’s harvesting, transport and forestry partners, who are independent contractors, are considered value chain workers. The human rights impact assessment for these worker groups highlighted in particular the potential negative impacts on health and safety, to which employees of suppliers involved in wood procurement, investment projects, and maintenance

shutdowns at production units are particularly vulnerable. In investment projects, potential negative impacts on equality, working hours and pay were identified. These particularly affect women and minorities. In addition to these key impacts, the assessment also pointed out a potential negative impact on the working conditions of workers in the forest management value chain, especially during the forest regeneration stage.

The most significant potential negative impacts in the upstream value chain are related to the value chains of chemicals, binders, coatings and pigments, as well as mill equipment, which are long and may extend to countries with a high risk of human rights impacts. The potential negative impacts on these value chain workers are related to poor working condi- tions, labour exploitation and occupational safety.

In the downstream value chain, potential negative impacts are primarily concentrated in the sale of the company’s products to globally operating customers, some of whose branch of industry or country of location has been identified to involve a higher risk of human rights violations. The human rights situation of countries is taken into account when assessing risks associated with customer relationships. A country’s poor human rights situation primarily affects vulnerable workers of customer companies or their value chains. For example, the tobacco industry’s value chains are generally associated with potential negative impacts particularly regarding women’s and children’s rights and on occupational safety in the production process.

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Policies

Sustainability related to the employees of Metsä Board’s suppliers is guided by Metsä Group’s Supplier Code of Conduct, approved by the company’s Corporate Leadership Team, and the safety management system. Metsä Board’s minimum requirement in supply agreements is that suppliers commit to Metsä Group’s Supplier Code of Conduct or equivalent supplier-specific principles. Metsä Board does not have separate policies for downstream value chain workers. To ensure sustainability in the down- stream value chain, Metsä Board carries out due diligence in accordance with its Know Your Business Partner process, which is discussed under G1 – Business conduct .

One of Metsä Board’s strategic programmes focuses on safe and effi- cient operations and organic growth. The programme’s focal areas include the continuous improvement of occupational safety. One of the goals is to reduce the number of work-related accidents.

Working conditions

The Metsä Group Supplier Code of Conduct includes several requirements related to the working conditions of suppliers’ employees, with which suppliers must comply:

Fair employment practices

A living wage as required by laws and regulations

Freedom of association and collective bargaining

Respect for privacy

Anti-harassment

The responsibility for implementing the Supplier Code of Conduct lies with those in charge of procurement, and the person ultimately accountable for its principles is the President and CEO of Metsä Group.

Health and safety

The Supplier Code of Conduct requires suppliers to provide a safe and healthy working environment to prevent accidents, injuries and illnesses, and to ensure that employees are aware of and adequately trained in these issues. Suppliers must have an occupational health and safety management system according to ISO 45001 or an equivalent system, as applicable.

Metsä Board’s occupational safety is guided by the safety management system, comprising the Corporate Security Policy and the safety princi- ples, standards, processes and work instructions. The safety management system encompasses all the employees of contractors working in Metsä Board’s operations, and the system’s requirements are the same for the company’s own workforce and contractors. The implementation of safety policies is the responsibility of Metsä Board’s CEO in accordance with the requirements specified by Metsä Group’s senior management. The respon- sibilities related to safety policies are described under S1 – Own workforce .

The Safety Management Standard for Metsä Group Service Providers specifies requirements for the work management and supervision, employee competence, safety reporting, and permits to work of service providers working in Metsä Board’s operations.

Other work-related rights

The Supplier Code of Conduct specifies many binding requirements concerning other work-related rights of suppliers’ employees:

Respecting internationally recognised human rights in accordance with the United Nations’ Universal Declaration of Human Rights and the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work.

Acting in compliance with the UN Guiding Principles on Business and Human Rights.

Taking action to remedy any adverse human rights impacts. Special attention must be paid to any adverse impacts on groups or individuals that may be at higher risk of vulnerability, such as migrant workers.

Prohibiting the use of any form of child labour and forced labour, includ- ing modern slavery and trafficking in human beings.

In relation to the upstream or downstream value chain, no confirmed 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.

Engaging with value chain workers about impacts

The need for interaction with suppliers’ employees or their representatives is highlighted when suppliers’ employees work in operations comparable to Metsä Board’s own operations at mills or on construction sites, for example. In other respects, the views of suppliers’ employees are conveyed indirectly through supplier management activities such as cooperation meetings and surveys and audits. Metsä Group’s Procurement and Logis- tics function is responsible for the implementation of these activities and for considering the results. The effectiveness of interaction with suppliers’ employees and the progress of cooperation are monitored through a supplier cooperation survey conducted approximately every two years. Cooperation is supported by a communication channel called Supplier Portal intended for the management of supplier cooperation, which pro- vides information about training, instructions and topical matters. Supplier management practices are discussed under G1 – Business conduct .

Safety is continuously developed and monitored with service providers working at the mills and in construction projects. Service providers’ safety performance is monitored in large investments such as construction pro- jects. Regular on-site safety talks are organised for the project employees, and observed safety deviations are actively addressed. A contact person from the applicable trade union and a health and safety representative are assigned to projects. A model for combating the grey economy is used in construction projects, and project employees can also use the notification channel to report any concerning issues they observe.

The communication methods described above are intended to gain an understanding of the views of workers in the upstream value chain, includ- ing those in positions that are particularly vulnerable to impacts. Metsä Board does not have a process for directly communicating with workers in the downstream value chain. Communication with corporate customers is discussed under S4 – Consumers and end-users .

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Report of the Board of Directors | Metsä Board Annual review 2025

Processes to remediate negative impacts and channels for value chain workers to raise concerns

In the Supplier Code of Conduct, the supplier commits to rectifying any non-compliance with the code. Suppliers must also ensure that their employees and stakeholders can raise concerns or grievances, and that there are appropriate practices for handling such cases.

The rectification of any deviations identified based on supplier assess- ments and audits is monitored. A model for combating the grey economy, as well as on-site spot checks, are in use in construction projects. Suppliers’ satisfaction and awareness of the means of communication and interaction are assessed with supplier surveys. A more detailed description is provided under Actions in this section and under G1 – Business conduct .

Any non-compliance related to working conditions, health and safety or other human rights is handled in accordance with Metsä Board’s escalation process, and in large investment projects, in accordance with the project’s management model. The idea is first to offer suppliers the chance to rectify their way of working. If the supplier is unwilling or unable to rectify their way of working, cooperation with the supplier is discontinued. The most serious cases are presented for processing to Metsä Board’s Corporate Leadership Team.

Compliance and Ethics Channel

Workers in the value chain can report any ethical concerns or non-compli- ance with legislation they detect in connection with their cooperation with Metsä Board through Metsä Group’s Compliance and Ethics Channel or to their contact person at Metsä Board. The notification procedures are discussed in the general safety induction for service providers’ employees working in the company’s operations. To increase awareness of the Com- pliance and Ethics Channel, the channel is promoted in the Supplier Portal, and in information channels and on posters on the sites. In accordance with the Supplier Code of Conduct, the suppliers’ employees can report incidents of non-compliance through the Compliance and Ethics Channel. The Compliance and Ethics Channel, raising concerns and the processing of notifications are discussed in greater detail under G1 – Business conduct .

Working conditions

Health and safety

Safety is continuously developed and monitored with service providers working at the mills and in construction projects. Service providers are required to engage in systematic and proactive safety work such as safety observations, walks and talks. Service providers’ employees record their safety observations in the HSEQ system. The recording of safety observations is enabled across the value chain. Safety observations are discussed in connection with daily meetings. Metsä Board does not accept countermeasures against whistle-blowers. If required, whistle-blowers may also choose to submit a report anonymously through the Compliance and Ethics Channel.

Accidents and hazardous situations are investigated thoroughly in coop- eration with service providers. In the case of serious accidents, the author- ities are also involved. The investigation creates conditions for avoiding similar situations and identifying any shortcomings in safety management.

When the investigation report is completed, a summary of the investigation is also distributed to all other Metsä Group business areas.

If shortcomings are observed in the service providers’ occupational safety, the same approach is followed as in other incidents of non-com- pliance concerning suppliers – that is, the provider is first offered the opportunity to rectify their way of working. If the service provider is unwilling or unable to rectify their way of working, cooperation with the service providers is discontinued.

In 2025, Metsä Board introduced the Fair & Just operating model for both its own employees and service providers. During the year, a total of four instances of safety non-compliance by service providers were identi- fied under the model. None of these cases resulted in accidents, but each was assigned a sanction in accordance with the operating model. More information about the model is provided in section S1 – Own workforce .

Actions

In 2025, Metsä Board’s operations did not cause severe human rights impacts, and no confirmed severe human rights issues or human rights violations in the upstream or downstream value chain were brought to the company’s attention. Less severe work-related accidents causing personal injuries, incidents and complaints are discussed under S1 – Own workforce .

Metsä Board’s actions seek to mitigate negative impacts and produce positive impacts on value chain workers. The measures are continuous and annual. Processes are developed in line with continuous improvement. Metsä Board has not identified significant operating or capital expenditure allocated to actions concerning value chain workers.

Working conditions

Continuous actions

A background check is carried out on new suppliers, excluding private forest owners and certain low-risk suppliers. In addition, compliance is monitored continuously during the supplier relationship. Any known human rights violations and negative publicity related to human rights are reviewed as part of the background check. More detailed supplier assessments and audits are conducted for the most important suppliers, but also for suppliers whose branch of industry, country or performance involves a heightened risk related to sustainability or availability. Supplier assessments and audits are conducted to ensure that each supplier has adequate means to recognise and minimise impacts on the working conditions and other work-related rights of their employees. Among other things, evaluations seek to ensure that the companies have adequate proactive measures for ensuring occupational safety, as well as a written code of conduct and an anonymous reporting channel for employees. Audits include observations of working conditions and interviews with employees if required.

Some of the key actions to safeguard the rights of value chain workers in Metsä Group’s wood supply include the requirement that contractors com- mit to sustainability requirements, background checks of entrepreneurs, close cooperation with the network of entrepreneurs, compliance with forest certification schemes and chains of custody (PEFC and FSC) and ISO standards (ISO 9001, 14001, 45001), as well as validation of operations by independent parties.

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In most large strategic construction projects, the subcontracting chain’s sustainability is ensured proactively with the operating model for combat- ing the grey economy. It ensures that companies in the subcontracting chain comply with laws and collective agreements, and handle their taxes and other obligations appropriately. The backgrounds of businesses are checked at the offer stage, and spot checks are conducted regularly to detect any deviations.

To ensure the sustainability of suppliers, customers and other coopera- tion partners, Metsä Board follows third-party due diligence with its Know Your Business Partner background checks, which are discussed in more detail under G1 – Business conduct .

Supplier management practices are discussed in greater detail under G1 – Business conduct .

Actions taken during the reporting year

During 2025, Metsä Group launched risk-based internal audits of its contractors providing wood supply services. The audits are voluntary and focus on the work permits, training, use of protective equipment, and working conditions of contractors’ employees, for example. In addition, an anonymous survey on working conditions was piloted with selected contractors.

Health and safety

Continuous actions

The general safety induction dealing with hazards and risks in the work environment is mandatory for service providers working at Metsä Board’s production units and construction sites. Before beginning to work on Metsä Board’s site, suppliers also receive a work-specific safety induction and permits to work. Service providers must assess the risks in their own work, prepare for them with a safety plan and submit their plan to Metsä Board. Service providers participate in Metsä Board’s safety walks and risk assessments. Work-related accidents that occur in the service providers’ operations at Metsä Board are registered in the HSEQ system. Accidents and reported safety observations are monitored continuously. In con- struction projects, the safety performance of different service providers is monitored, and any safety deviations observed are actively addressed.

Metsä Fibre, Metsä Board’s associated company, organises regular cooperation forums with key service providers to discuss the conditions and joint development needs of safety cooperation. A key safety develop- ment measure in the next few years is to expand cooperation forums to Metsä Board.

Requirements for occupational safety training have been set for Metsä Group’s wood supply contractors, and they participate in regular safety walks on the loading and unloading sites of production units and terminals. In addition, a risk assessment is conducted at all forest worksites.

The wood supply workers use an application designed for working alone in the forest.

Actions taken during the reporting year

In 2025, key joint targets and operating models were defined for the development of service providers’ safety, with the aim of further improving workplace safety in cooperation with service providers. The defined oper- ating models are particularly important for the preparation of safety plans and risk assessments, setting objectives for proactive security work, and for specifying the content of cooperation regarding auditing, for example.

Metsä Group’s Wood Supply continued the safety management training for contractors that was started last year. In addition, the e-learning course on working near power lines, which is mandatory for wood harvesting personnel, contractors and their employees, was updated. A new service to identify and consider the key environmental and safety aspects of each site was introduced to support the planning and implementation of wood pro- curement. During the year, minimum requirements for timber cranes were also introduced, transition periods were defined, and recommendations were issued on the best technical solutions for improving operator safety.

Other work-related rights

Supplier management practices, including audits to verify the implementa- tion of social responsibility, are discussed under Working conditions in this chapter. The auditors have been trained to detect risks related to forced labour and labour exploitation, for example.

Reporting principles for metrics

Total recordable incident frequency, contractor employees (TRIF)

The incident frequency has been calculated per million hours worked. The working hours of service providers have been estimated based on procurement costs. The number of accidents at work is reported under S1 – Own workforce . The metric has not been validated by an external party.

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Report of the Board of Directors | Metsä Board Annual review 2025

S3 – Affected communities

Material impacts, risks and opportunities related to affected communities

Material sub-sub-topic

Impacts

Value chain stage

Time horizon

Risks and opportunities for Metsä Board

Value chain stage

Time horizon

Communities’ economic, social and cultural rights

Land-related

impacts

Impacts of production units and wood supply that promote employment, livelihood and tax revenue, especially in small localities.

Opportunity: Improved management of sustainability impacts and strengthening of the company's reputation as a responsible operator through stakeholder engagement

Any negative environmental impacts of production units such as noise, odour or dust

Risk: Weakening of the appreciation of the company's activities and its reputation as a responsible operator as a result of insuffi- cient stakeholder engagement

Commercial forest use may have an impact on the recreational use of forests compared with old-growth, natural or primary forests.

Rights of indigenous peoples

Free, prior and

informed consent

Potential impacts of wood supply in Northern Finland and Northern Sweden on the ability of the Sámi to pursue their livelihood

Risk: Insufficient consideration of indigenous peoples may weaken understanding of the impacts of operations, the quality of deci- sion-making and the company's reputation as a responsible operator

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

Upstream value chain

Own operations

Downstream value chain

Short-term (less than one year)

Medium-term (1–5 years)

Long-term (more than 5 years)

Targets

Metsä Board’s 2030 sustainability targets, and their setting and moni- toring, are discussed in greater detail under Sustainability governance and strategy and Material sustainability-related impacts, risks and opportunities.

Sustainability targets related to the environment and the supply chain are primarily designed to reduce – directly or indirectly – the negative impacts of Metsä Board’s operations or promote positive outcomes for affected communities.

Affected communities

The main communities affected by Metsä Board include forest owners, local communities in mill localities, the nature around the mills and the people who earn their livelihood from it, as well as other interested parties such as indigenous peoples (the Sámi), and NGOs. In mill localities, Metsä Board’s impacts on communities result directly from the company’s own operations. In wood supply areas, the impacts are caused in the value chain. If realised, the impacts are generally systematic, which is why the affected communities are considered in investment planning, and in mill and wood supply operations. Individual impacts may occur during exceptional situations at mills, for example.

Policies

Sustainability concerning affected communities is guided by the Code of Conduct and the Supplier Code of Conduct, which include commitments to human rights. 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 affected communities, no confirmed 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 . In addition to the company’s own workforce and workers in the value chain, the commitments concern all affected communities.

The hearing of affected communities is guided by the production units’ environmental permits and environmental management systems, among other things. These policies are discussed under environment-related sections E1 , E2 , E3 , E4 and E5 , and in this section, under Engaging with affected communities about impacts .

Special attention is paid to affected communities in the operating model for stakeholder engagement. Metsä Board also strives to develop its operations by regularly surveying opportunities for cooperation.

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Engaging with affected communities about impacts

For example, Metsä Board communicates openly on the impact of its oper- ations and products with the help of life cycle analyses and aims for active dialogue with stakeholders. The goal of stakeholder engagement is to ensure that stakeholders are met and heard, and that the company obtains feedback on its operations. Feedback is analysed, and it is taken into account in operational development and reported to senior management. The operating model for stakeholder engagement is described on page 29 .

The scope and frequency of engagement differs, depending on the stakeholder. Metsä Group’s Stakeholder Engagement unit aims to organise a bilateral meeting with each key stakeholder of Metsä Group at least once a year. Other engagement mechanisms include cooperation days, visits, and cooperation projects. No specific frequency has been defined for meetings with local communities. Instead, engagement takes place in the form of open house events, investment projects, meetings with the authorities or feedback channels, for example. The company engages directly with community members such as the residents of mill locations or their representatives such as the local authorities.

In 2025, the first community feedback survey was conducted to determine what local communities thought about the sustainability and reliability of Metsä Group’s operations. Based on the survey results, the key development needs were related to communication and interaction with local communities, and the promotion of social wellbeing within local communities. Positive feedback was received on the economic impact of Metsä Group on the region, and on the environmental performance of forest use and forest management, for example.

Of indigenous peoples, the Sámi are affected by Metsä Board’s oper- ations especially in the context of wood supply. In the home region of the Sámi, Metsä Group engages in dialogue about the coordination of reindeer husbandry and forestry with stakeholders, including forest owners and reindeer owners’ associations, and ensures locally that wood supply does not jeopardise the conditions for reindeer husbandry.

Processes to remediate negative impacts and channels for affected communities to raise concerns

Metsä Board engages in continuous dialogue with its stakeholders. The implementation of large projects such as new production units or production lines always includes an environmental impact assessment, conducted in advance, which also involves hearing local communities and other stakeholders. In addition, local communities have a statutory right to participate in the mills’ environmental permit processes by submitting reminders about and views on environmental permit applications, which are considered in the permit process. In other matters, the affected communities can raise concerns by directly contacting local operations through the production units’ contact persons, Metsä Board’s Commu- nications or Metsä Group’s Stakeholder Engagement unit, for example. The feedback received is processed, a response is sent to the feedback provider, and an entry is made in the HSEQ system as soon as possible. Open house events organised at Metsä Board’s production units are an established way of informing local residents and other interested parties about Metsä Board’s operations. Metsä Board aims to keep the public widely informed about events through different media such as newspapers and social media. It is also possible to provide feedback and ask questions through the company’s website.

To remediate any negative impacts, the company acts without delay and in cooperation with the local and regional authorities if required. Social sustainability, including local communities and the customs, traditions and justice systems of indigenous peoples, has been taken into account in the requirements of forest certification and the Chain of Custody. In any violation of these, an investigation is launched in accordance with Wood Supply’s due diligence system, and corrective action is taken if required. To remedy any environmental deviations, Metsä Group, in charge of the company’s wood supply, has introduced voluntary nature compensation as part of regenerative forestry, which will outweigh the harm to nature resulting from any non-compliance with legislation. The operating model ensures that corrective action remediating non-compliant conduct results in greater benefit than harm to nature. Nature compensation is applied in accordance with the Nature Conservation Act and Forest Act, which play a key role for biodiversity. The compensation model is being developed, and it will be applied to detected deviations retroactively from 2023. During 2025, an independent expert group participated in determining the nature hazards and compensation measures for the nature sites, and the operating model and its methods were developed with the future in mind.

Compliance and Ethics Channel

The affected communities can also report any ethical concerns or non-compliance with legislation through Metsä Group’s Compliance and Ethics Channel. In the Supplier Code of Conduct, the supplier commits to rectifying any non-compliance with the code. The Compliance and Ethics Channel is described under G1 – Business conduct .

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Report of the Board of Directors | Metsä Board Annual review 2025

Actions

In 2025, Metsä Board’s operations did not cause severe human rights impacts, and no confirmed severe human rights issues or human rights violations related to the affected communities were brought to the company’s attention. Incidents, complaints and severe human rights impacts are discussed under S1 – Own workforce .

Continuous actions

Actions for managing negative impacts and promoting positive impacts at mill localities include systematically reducing environmental impacts, engaging local communities, and increasing initiatives that improve local cooperation and quality of life through better employment and recreational opportunities, for example. In wood supply, the main local stakeholders are taken into account, and compliance with certification requirements is ensured.

The regenerative forestry strategy is a solution that Metsä Group has been systematically developing to seriously address stakeholder concerns – such as those from NGOs – regarding biodiversity loss and climate change. In addition to regenerative forestry, Metsä Group is promoting other actions such as the voluntary METSO forest conservation programme and its implementation. Metsä Group offers its forest-owner members regenerative forestry service solutions such as the Metsä Group Plus service. These actions are discussed in greater detail under E4 – Biodiversity and ecosystems .

Actions taken during the reporting year

In 2025, Metsä Group announced that it would establish a Metsä Conservation Foundation to protect forests with high biodiversity value. In addition, Metsä Board continued to implement its regenerative land-use model.

A model for regenerative land use has been piloted on the Kemi mill site since 2023. The model aims to strengthen the state of nature in the built environment by cultivating native and local species, removing harmful inva- sive species, promoting stakeholder cooperation, and examining how work that supports biodiversity can be combined with industrial production, for example. The planning and implementation of projects that strengthen the state of nature is conducted in collaboration with experts and local stakeholders such as organisations and local authorities.

Further information about these actions, including the costs of regenerative land-use projects during the reporting year, is provided under E4 – Biodiversity and ecosystems . Metsä Board has not identified other significant operating or capital expenditure allocated to actions concerning affected communities.

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S4 – Consumers and end-users

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

Material sub-sub-topic

Impacts

Value chain stage

Time horizon

Risks and opportunities for Metsä Board

Value chain stage

Time horizon

Personal safety of consumers and end-users

Health and safety

The impact of potential product safety deficiencies on the health and safety of consumers and end-users

Risk: Reputational damage among existing and potential new customers, consumers, and end-users, potential liabilities for compensation, and other costs related to damage limitation

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

Upstream value chain

Own operations

Downstream value chain

Short-term (less than one year)

Medium-term (1–5 years)

Long-term (more than 5 years)

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 .

Affected consumers and end-users

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. In addition, product safety is particularly important in food packaging. The impacts are not systematic but are most likely related to isolated incidents, such as product defects.

In addition to the health and safety impacts and risks presented in the table above, other impacts, risks and opportunities related to consumers were identified in the double materiality assessment. These are described under E1 – Climate change , E4 – Biodiversity and ecosystems and E5 – Resource use and circular economy .

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.

Metsä Board respects internationally recognised human rights in all its operations. The company is committed to rectifying any negative human rights impacts in accordance with the UN Guiding Principles on Business and Human Rights. 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 meet the needs and expectations of customers – and thus consumers and end-users. Metsä Board’s Corporate Leadership Team is responsible for implementing the Quality Policy at Metsä Board.

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 sys- tems of Metsä Board’s production units are listed in the table on page 98 .

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Report of the Board of Directors | Metsä Board Annual review 2025

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

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 direct communication with consumers and end-users, but they can contact Metsä Board directly using the contact form on the company’s website.

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 by Metsä Board with the support of external parties such as research institutions if required. Management of quality deviations through processes, root cause analyses are conducted for quality deviations, and any required corrective action is taken. 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 noti- fications concerning Metsä Board’s products or any recalls of consumer packaging made from the company’s paperboard in 2025. 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 2025, 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. The actions are continuous and annual, and 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.

Continuous actions

Product compliance is monitored with the product safety process, which includes raw material management, compliance assessment and product testing, both internally and with external cooperation partners. Metsä Board’s mills have ISO 22000 and FSSC 22000 food safety systems that cover food safety-related risks across the production and supply chain, and the functioning of systems is assured annually with internal and external audits. Metsä Board’s product safety specialists continuously monitor developments in legislation and requirements.

Production-related product safety risks are managed with methods such as the HACCP (Hazard Analysis and Critical Control Points), which is used at all Metsä Board production units. A HACCP hazard analysis is carried out whenever there are changes in essential processes or raw materials.

Metsä Board’s products are tested regularly in accredited laboratories to ensure their quality and safety. The laboratory analyses and detailed composition compliance analyses form the basis for the Product Safety Statement, which includes product-specific information about product safety and compliance.

Quality and safety are also monitored with the aid of reputation surveys, customer feedback and customer surveys. Metsä Board conducts quarterly monitoring and assessment of customer feedback related to any negative impacts on consumers and end-users. Any negative impacts are classified as material based on the type code of the customer feedback. The type codes monitored include foreign objects in products, purity of product, and sensory properties.

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G – Governance

G1 – Business conduct

Impacts, risks and opportunities related to business conduct

Impacts

Value chain stage

Time horizon

Risks and opportunities for Metsä Board

Value chain stage

Time horizon

Corporate culture

A safe working environment for employees thanks to actions promoting an ethical corporate culture, and conditions for ethical and reliable cooperation for stakeholders

Opportunity: The employees’ and other stakeholders’ positive experience of Metsä Board and the company’s reputation as an ethical and reliable operator strengthens.

Inadequate measures to increase employee commitment to an ethical corporate culture can lead to illegal or unethical business practices, unequal treatment and harassment

Risk: Financial losses resulting from illegal activities, dam- age to reputation as a responsible partner and operator, and a decline in employee job satisfaction and commitment as a result of any unequal treatment and harassment

Corruption and bribery

Prevention and detection: Actions and control mechanisms for preventing corruption and bribery offer stakeholders the oppor- tunity to cooperate with an ethical and reliable operator.

Opportunity: Stakeholders’ experience of Metsä Board and the company’s reputation as an ethical and reliable operator strengthen, which supports the improvement of performance and competitiveness

Incidents: The occurrence of corruption and bribery as a result of potentially inadequate preventive actions and control mechanisms

Risk: Significant financial penalties and damage to reputation and employer image resulting from corruption or bribery

Management of relationships with suppliers

The potential positive impact of requirements, monitoring mech- anisms, and sustainability cooperation on ethical performance and sustainability in the supply chain

Opportunity : A stronger reputation as a responsible partner and operator, and more intensive cooperation with suppliers, which supports the creation of long-term partnerships

Non-compliance with company or legal requirements in the supply chain as a result of potentially inadequate Metsä Board requirements and control mechanisms

Risk : Inadvertent support of operations that do not comply with the company’s values, which may endanger the reputation as a responsible partner and weaken supplier relations, causing the loss of the best partnerships

Unequal treatment of suppliers as a result of potentially inadequate training of procurement personnel and monitoring mechanisms

Protection of whistle-blowers

Possible retaliation against whistleblowers or victims resulting from shortcomings in ensuring the anonymity and confidentiality of whistleblowers

Risk: Declining trust in the Compliance and Ethics Channel. Failure to report suspected misconduct, which may result in non-detection of actions that violate values and ethical principles, financial losses, and a decline in job satisfaction and employer image

Political engagement and lobbying activities

Bringing views that promote the circular economy and emphasise the role of wood-based products to the forefront of public debate as a result of potentially successful lobbying

Opportunity: Political operators recognise the potential of the circular bioeconomy and the role of forests and wood- based solutions in climate change mitigation, improving the conditions of Metsä Board’s operations.

Advocacy that is inconsistent or contrary to Metsä Board's operating principles, and failure to exploit the potential of the bioeconomy and wood-based products as a result of potentially inadequate core messages and the application of ethical practices

Risk: Inconsistent presentation of identified essential key messages in political debate, which at worst could lead to regulatory risks materialising and damage to reputation as a responsible operator.

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

Upstream value chain

Own operations

Downstream value chain

Short-term (less than one year)

Medium-term (1–5 years)

Long-term (more than 5 years)

Metsä Board’s 2030 sustainability targets

2030 target

2025

2024

2023

Employee experience on ethical corporate culture implementation, ethics index (scale 0–100)

100

79

-

Share of certified wood fibre, %

100

92

91

Traceability of raw materials, share of total purchases, %

100

95

97

Suppliers' commitment to the Supplier Code of Conduct, share of total purchases, %

100

99.5

99.0

Supplier assessments and audits of core suppliers, %

100

77

79

68

MG: Joint sustainability target with partner suppliers, %

100

MG: The target has been set at the level of Metsä Group.

In 2024, ethics index monitoring was changed from actions-based to index-based, which is why comparison year 2023 is not available.

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Report of the Board of Directors | Metsä Board Annual review 2025

Metsä Board’s strategic 2030 sustainability targets, and their setting and monitoring, are discussed in greater detail under Sustainability governance and strategy and Material sustainability-related impacts, risks and opportunities .

Progress in targets

Employee experience of ethical corporate culture implementation – Progress towards the target was not made as planned, and the result remained unchanged from the previous measurement. Development actions will continue, including employee training using the new Code of Conduct e-learning course published in early 2026.

Share of certified wood fibre – In 2025, the progress towards the tar- get was slightly better than in the previous year. The certification target was updated, and starting in 2025, the new target is 100%. At Metsä Group, which is responsible for Metsä Board’s wood supply, the second half of 2025 saw the launch of actions to increase FSC certification, and a higher additional price has been paid for FSC certified wood since the beginning of November.

Traceability of raw materials, share of total purchases – In 2025, the traceability of raw materials remained at almost the same level as in the previous year.

Suppliers’ commitment to the Supplier Code of Conduct, share of total purchases – Suppliers’ commitment to the Supplier Code of Conduct remained at a high level in 2025.

Supplier assessments and audits of core suppliers – The target remained at the previous year’s level in 2025. EcoVadis sustainability assessments were used more extensively in supplier assessments.

Joint sustainability targets with partner suppliers – A sustainability target has been agreed with all current partner suppliers, which means the target has been achieved. In 2025, cooperation with partners continued through more detailed target setting and planning and, with certain suppliers, direct implementation.

The role of the administrative, management and supervisory bodies

The Compliance and Ethics programme is supervised by the Compliance Committee, composed of Metsä Group’s directors in charge of legal affairs, internal audit, HR, and compliance and ethics. In 2025, the Compliance Committee convened six (6) times.

Once a year, the director in charge of compliance and ethics presents a compliance and ethics review to Metsä Board’s Corporate Leadership Team and Audit Committee. In addition, the directors in charge of legal affairs, taxes, and compliance and ethics present a legal affairs, compli- ance and tax review twice a year to the CEO and CFO.

The Compliance Committee’s role in investigating ethical concerns is described under Mechanisms for identifying, reporting and investigating concerns .

All the members of Board of Directors have gained significant experience of good governance from their previous duties in operational management and/or as Board members in a listed company or another large corpora- tion. The Board members regularly complete training in the company’s insider guidelines.

Policies

The sustainability of Metsä Board’s business conduct is guided by appli- cable legislation, as well as the values, Metsä Group’s Code of Conduct and various policies approved by the company’s Board of Directors. Metsä Board is committed to operating in accordance with the UN Guiding Princi- ples on Business and Human Rights and requires the same of its business partners. Since 2003, Metsä Board has supported the UN Global Compact and its principles on human rights, employees, the environment and anti-corruption. Metsä Group’s Compliance function ensures compliance with legislation, the Code of Conduct, policies and internal guidance, trains personnel, and ensures that policies are up to date in cooperation with policy owners.

Metsä Group has 16 policies, three of which are public policies, and 13 are internal policies. The policies are mandatory, and all Metsä Board employees must comply with the principles and provisions they specify. Each policy sets out its targets, purpose, scope of application, responsible parties, and decision-making and change process. All employees are required to complete e-learning courses in the Code of Conduct and other key policies such as the Equality Policy, Data Protection Policy and Infor- mation Security Policy every three years. The Code of Conduct e-learning course presents Metsä Board’s key ethical principles and describes the best practices related to business sustainability through examples and exercises. An updated version of the Code of Conduct e-learning course mandatory for all employees was published in 2025.

Depending on the employees’ role, they are also required to complete e-learning courses on other policies such as the antitrust, procurement, agreement and legal affairs policies. In 2025, updated versions of advanced e-learning courses on data protection were released. One of them is for all supervisors, and the other is for sales and marketing person- nel. All employees are also required to complete an e-learning course on generative artificial intelligence published in 2025, which covers the basic principles of the responsible use of artificial intelligence.

As part of the corruption and bribery risk assessment conducted in 2025, classroom training about ethical business and anti-corruption prin- ciples was given to the entire sales organisation and strategic procurement personnel. The training sessions were preceded by a participant survey to identify risks of corruption and bribery. The results of the survey were used for planning the training content. In addition, a section developing super- visors’ capability of addressing ethical grievances and encouraging the reporting of grievances was added to the training offered to supervisors. Ethical operations and doing the right thing are also part of the induction of new white collars and apprenticeship trainees.

The completion of e-learning courses and classroom training is regularly monitored by the Compliance Committee, which supervises the Compli- ance and Ethics programme, and the results are reported once a year to the Audit Committee of the company’s Board of Directors. The completion percentage of the Code of Conduct e-learning course is presented in the Completion of e-learning courses table.

A culture of diversity, equality and inclusion (DEI), and the implemen- tation and development of an ethical and respectful corporate culture, is one of the focal areas of the Motivated people strategic programme. The programme’s focal areas and goal are discussed under S1 – Own workforce.

The implementation and development of the culture of doing the right thing are measured with the ethics index, calculated based on the ethics

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statements in the Personnel survey, which measures the employees’ experience of ethics in the company’s operations. The survey conducted in 2025 gave no reason to consider financial misconduct, corruption, conflicts of interest, inappropriate influencing of partners’ decision-making and data protection breaches as material risks. The results of the ethics statements will be discussed on all sites by the end of March 2026. Each site will define development measures for 2026 for the correction of the detected shortcomings.

Corruption and bribery risks are assessed as part of Metsä Group’s risk management process. Of the company’s internal functions, sales and marketing, procurement and lobbying have been identified as those most susceptible to corruption and bribery. The actions for preventing and detecting corruption and bribery are described on page 94 .

Metsä Board annually participates in several environmental, social responsibility and business practice assessments conducted by third par- ties such as CDP, EcoVadis, ISS, Sustainalytics and MSCI. Metsä Board’s partners can also assess Metsä Board’s sustainability through the Sedex system. In addition, third-party SMETA audits (Sedex Members Ethical

Trade Audit) are conducted on Metsä Board’s sites. In 2025, a SMETA audit was conducted at the Kemi paperboard mill.

To ensure the sustainability of its suppliers, customers and other partners, Metsä Board follows third-party due diligence in its Know Your Business Partner process, in which the partner’s background is checked for any risks related to trade sanctions, corruption, money laundering, human rights violations, environmental offences and various other misconduct before a binding agreement is concluded, as well as during the cooperation relationship by means of continuous monitoring. In 2025, the process was further developed by harmonising the data management model, clarifying responsibilities and roles, and providing training in the key content of the Know Your Business Partners principles published in 2024. Relationships with goods and service suppliers are described in more detail on page 93.

In 2022, Metsä Board ended all business related to Russia and Belarus due to Russia’s military aggression against Ukraine. Following the business transaction in 2024, Metsä Board and Metsä Group have no more holdings in Russia.

Summary of key sustainability-related policies

Policy

Key content

Scope of application

Monitoring process

Highest accountable level

Code of Conduct

Defines the commitment to operate ethically, respect human rights, promote equality and safety, protect the environment and prevent corruption and abuse. Partners are required to commit to equivalent principles.

All companies belong- ing to Metsä Group and their employees

Monitoring of mandatory e-learning comple- tion rates for all employees, the Compliance and Ethics Channel, ethics index consisting of ethical questions in personnel surveys

Metsä Group, President and CEO

Supplier Code of Conduct

Covers the key elements of ethical business operations, such as respect for human rights and the basic principles of working life, environmental responsibility, safe and non-discriminating work environments, and the preven- tion of corruption and bribery.

Suppliers of Metsä Group companies and the suppliers’ employees

Percentage of Metsä Group's goods and service suppliers committed to the require- ments of the Supplier Code of Conduct, the Compliance and Ethics Channel, and supplier assessments such as EcoVadis

Metsä Group, President and CEO

Environmental Policy

Defines a commitment to sustainable forestry, integrates environmental impact considerations into operations and supply chain, promotes continuous improvement of envi- ronmental efficiency, mandates the phasing out of fossil energy in production and prioritizes proactive stakeholder cooperation.

All companies belong- ing to Metsä Group and their employees

Monitoring of mandatory e-learning course completion rates for all employees and the achievement of sustainability targets

EVP, Stakeholder Engagement, Metsä Group

Human Resources Policy

Covers principles related to personnel concerning re- sponsible conduct, management and resource planning, recruitment, pay and rewards, and personnel and organi- sational development.

All companies belong- ing to Metsä Group and their employees

The Personnel survey and the Employee Engagement Index consisting of questions related to the employee's own work, team, management and company, quarterly Pulse survey

EVP, HR, Metsä Group

Equality

Policy

Defines Metsä Group's position on equality and non-dis- crimination in all working life activities. Metsä Group is committed to treating everyone equally, fairly and respectfully, and does not tolerate discrimination in any form.

All companies belong- ing to Metsä Group and their employees

Monitoring of mandatory e-learning courses’ completion rates for all employees, the gender distribution in supervisory and management positions, and the Metsä for All index, which is based on DEI statements in the Personnel survey.

EVP, HR, Metsä Group

Corporate Security

Policy

Defines the key principles, objectives and operating mod- els for overall security management. The main objective is to ensure the smooth continuity of Metsä Group’s oper- ations and to protect the Group’s companies, employees and other important stakeholders, information, assets, and operating environment from damage, reputational harm, misconduct, and criminal activity.

All companies belong- ing to Metsä Group and their employees

Risk management process, occupational safety training, background check process (Know Your Business Partners)

Metsä Group’s Group General Counsel

Data Protection Policy

Defines the principles and rules that must be followed when processing personal data. The policy aims to ensure privacy protection and the implementation of related rights, as well as to manage the risks associated with non-compliance.

All companies belong- ing to Metsä Group and their employees

Data protection management model, monitoring of mandatory e-learning courses’ completion rates for all employees, advanced data protection e-learning courses updated in 2025

Metsä Group’s Group General Counsel

Quality Policy

Defines Metsä Group's internal targets and policies to ensure the quality and compliance of operations and products.

All companies belong- ing to Metsä Group and their employees

Continuous quality control, monitoring, and measurement at production units, internal and external assessments of certified quality systems

Metsä Group, President and CEO

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Report of the Board of Directors | Metsä Board Annual review 2025

Mechanisms for identifying, reporting and investigating concerns

Employees and stakeholders are encouraged to report any ethical concerns and non-compliance with the law related to Metsä Board’s oper- ations. Observations can be reported to the supervisor, local management, HR and the Compliance Committee, or through Metsä Group’s Compliance and Ethics Channel, which is available in ten languages to all stakeholders on the company’s website. Reports can be made anonymously. The chan- nel’s technical implementation is handled by an external service provider.

The Personnel survey’s ethics statements and open feedback are used to monitor the effectiveness of the Compliance and Ethics Channel, other reporting methods, and the investigation process for reporting and handling concerns. In addition to e-learning courses, awareness of the Compliance and Ethics Channel is promoted by improving the channel’s visibility with posters supplied to production units and in the Supplier Portal used to manage supplier cooperation. Moreover, satisfaction with and awareness of engagement methods are assessed as part of supplier surveys. No separate assessment is currently conducted of the down- stream value chain’s, affected communities’ or consumers’ and end-users’ awareness of and confidence in reporting methods or the effectiveness of reporting methods among these groups.

Every breach or violation, and suspected breach or violation, of which the company becomes aware is investigated. The investigation is supervised by the Compliance Committee. The committee is tasked with monitoring that the consequences of the investigations are applied consistently in cases of equal gravity. Corrective actions must be adequate as described in the company’s Code of Conduct and the Principles on non-compliance notifications and the related investigation. Any illegal activities are reported to the authorities. Neither the person investigated nor their supervisor participates in the investigation of the breach or suspected breach. If called for by the significance of the breach under investigation, the Compliance Committee reports the incident to Metsä Board’s management and Board of Directors at a regular meeting, or immediately if required.

The cases are divided into the following categories: fraud or other criminal behaviour; corruption and bribery; competition law; conflicts of interest; employee matters; discrimination or harassment; privacy and information security; occupational safety; the environment; breaches of the Supplier Code of Conduct; and other reports. Crimes against the company and attempts of such are also taken into account in the number of reports.

In 2025, no confirmed cases of bribery or corruption were brought to the company’s attention. In addition to the principle of continuous development in line with the company’s Compliance & Ethics programme and the Anti-Corruption principles published in 2024, a survey of bribery and corruption risk was conducted in 2025.

In 2025, Metsä Board was made aware of incidents that might have had a direct or indirect negative impact on the company’s human rights obligations. Incidents, complaints and severe human rights impacts are discussed under S1 – Own workforce . Incidents concerning the occupational safety and other work-related rights of suppliers’ employees are discussed under S2 – Workers in the value chain . None of the reports of inappropriate behaviour to the company concerned forced labour or the use of child labour.

The changes required by the EU Whistleblowers Directive (EU 2019/1937) in Metsä Board’s operating countries have been taken into account in the Compliance and Ethics Channel, the investigation

of reported incidents, and the protection of whistleblowers over the 2022−2024 period as local legislation in EU Member States has entered into force. The company is committed to fairly investigating all reports submitted in good faith and adopting the required actions based on the investigation and its results. The company is also committed to protecting the rights and privacy of people who report breaches in good faith. These commitments have been confirmed in the company’s Code of Conduct, and the principles on non-compliance notifications and the related investigation, which have been updated to meet the requirements of the Whistleblowers Directive. The Compliance Committee defines the required actions to ensure that the prohibition of countermeasures and the prevention of reporting is followed. Whistleblowers are requested to immediately report if they suspect any countermeasures. The prohibition of countermeasures is emphasised in the investigation of incidents. In cases involving a higher risk of countermeasures, a follow-up contact will be organised if required. In 2025, no cases of countermeasures against whistleblowers were brought to the company’s attention.

Management of relationships with suppliers

Supplier management practices

Metsä Board’s wood supply is ensured by Metsä Group’s Wood Supply and Forest Services. The procurement of other raw materials and services is centrally handled by Metsä Group’s Procurement and Logistics unit. The related procurement process seeks to ensure that the company’s partners operate sustainably to minimise any risks in the supply chain related to matters such as the environment, health, corruption, the use of child labour and human rights violations.

As a minimum requirement in supplier selection, suppliers are required to commit to the Metsä Group Supplier Code of Conduct or their own equivalent principles and to pass the background checks. Agreements may also include more specific sustainability requirements related to occupa- tional safety, product safety or environmental management, for example. These requirements apply to industrial wood suppliers and intermediaries in wood supply, and other raw material and service providers.

To ensure the sustainability of suppliers, Metsä Board follows third-party due diligence in its Know your Business Partner background check, as described under Policies .

The standard payment term in Metsä Board’s general terms and conditions for purchases is 60 days net. However, this can be reconsidered individually in the case of smaller suppliers, for example. Metsä Board is not party to any legal proceedings due to late payments.

Wood supply

Metsä Board uses wood from Northern European forests as its main raw material. Wood and purchased pulp account for 90% (89) of the company’s raw material consumption, measured by weight. All the pulp and high-yield pulp used by Metsä Board is either produced by itself or procured from its associated company Metsä Fibre.

Metsä Group has wood supply organisations in Finland and Sweden. The company works in close cooperation with local contract entrepreneurs in harvesting, transport and forestry work. All the countries from which wood is procured have issued legislation requiring the renewal of forests after regeneration felling.

Metsä Group requires wood suppliers to commit to wood sustainability requirements with an agreement, chain of custody certificate and their own

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sustainability assurance, which includes environmental and sustainability requirements and obligations for the wood supplier and forest owner.

The wood fibre’s sustainability and traceability are ensured by practices which meet the requirements of the EU Deforestation Regulation (EUDR), PEFC Chain of Custody and FSC Chain of Custody. In 2025, Metsä Board has continued to update its due diligence system to comply with the requirements of the Deforestation Regulation. The company has conducted country-specific risk assessments in accordance with EUDR requirements. Based on these assessments, all wood is sourced from low- risk countries. Metsä Board assesses wood supply practices with internal and third-party audits annually. The audits focus on matters related to environmental and social responsibility, as well as on the traceability of wood fibre in Metsä Board’s production and subcontracting. Metsä Board aims for certified wood to account for 100% of the wood fibre used by the company by 2030. The share of certified wood fibre in 2025 is presented under Metsä Board’s 2030 sustainability targets . Non-certified wood is also required to be of a sustainable origin, and the wood always meets at least the requirements for PEFC Controlled Sources and FSC Controlled Wood. Metsä Board’s policies concerning indigenous peoples are discussed under S3 – Affected communities .

Procurement of wood fibre by country, %

2025

2024

Finland

55

Sweden

35

Baltic countries

11

9.0

Other countries

0.001

1.5

Procurement of other raw materials and services

In addition to the Know Your Business Partner background checks, more detailed supplier assessments focus on the core suppliers, and on suppliers operating in industries with identified potential risks related to human rights, corruption or the environment. Suppliers’ sustainability and supplier-related risks are assessed with the EcoVadis tool, surveys and supplier audits.

Metsä Group, an external HSEQ cluster and another external party if required conduct annual supplier audits focusing on ethics, environmental responsibility, occupational safety and quality. The audits are conducted on-site. The supplier assessments and audits are used as the basis for making development proposals and monitoring any corrective action taken. The results are the responsibility of a third party or a Metsä Group employee who is not responsible for suppliers. In 2025, no serious devia- tions were detected in supplier assessments and audits.

To ensure the equal treatment of suppliers, the procurement employees are trained to disqualify themselves in decisions that may involve conflicts of interest. A written commitment to this is required in the procurement process. Approximately every two years, suppliers can respond to an anon- ymous survey concerning the smoothness and fairness of cooperation and factors contributing to these matters. The survey results are submitted to the suppliers, and measures to improve procurement practices are adopted based on them. The procurement employees have annual finan- cial performance targets related to matters such as conducting supplier sustainability assessments and monitoring improvements proposed by suppliers.

The company’s target is to agree joint sustainability targets and measures to achieve them with all its partner suppliers. The management of environmental impacts in cooperation with suppliers is discussed in greater detail under E1 – Climate change . Another target is to know the origin – or at least the country of manufacture – of all the company’s raw materials by the end of 2030, including wood, packaging materials and process, basic, and coating chemicals.

Annual monitoring of suppliers and raw materials ensures that Metsä Board’s products comply with statutory and Metsä Board’s own stringent product safety requirements. Product safety is discussed in greater detail under S4 – Consumers and end-users .

New supplier background checks, %

2025

2024

Share of suppliers for which a Know Your Business Partner background check was made

97

94

Prevention and detection of corruption and bribery

Metsä Board complies with Metsä Group’s principles and practices for preventing and detecting corruption and bribery. The Code of Conduct, which guides ethical operations, prohibits corruption and bribery. It also includes principles for avoiding conflicts of interest, crucially linked to anti-corruption, and principles on gifts and hospitality. In addition, Metsä Group has public Anti-Corruption principles that supplement the Code of Conduct. Metsä Group is committed to anti-corruption and anti-bribery in its own operations and in relation to its partners. A similar prohibition is included in Metsä Group’s Supplier Code of Conduct. Anti-corruption and anti-bribery efforts contribute to Metsä Group’s 2030 sustainability targets concerning a responsible corporate culture and supply chain.

The following are the main measures for preventing and detecting corruption and bribery:

Training in the Code of Conduct and other policies guiding Metsä Group’s operations (discussed in greater detail under Completion of e-learning courses ).

The Anti-Corruption principles published in 2024 and related communi- cation and training.

The ethics index used to measure the employees’ experience of ethics in business and to identify areas of development (under Metsä Board’s 2030 sustainability targets ).

Assessment of corruption and bribery risks as part of Metsä Group’s risk management process, and a separate corruption and bribery risk assessment conducted by Metsä Group in 2025 (see Mechanisms for identifying, reporting and investigating concerns for more details).

The Compliance and Ethics Channel available to all internal and external stakeholders. A standard process has been defined for processing reports (discussed in greater detail under Mechanisms for identifying, reporting and investigating concerns ).

Due diligence in ensuring the sustainability of partners, and the required background checks (third-party due diligence) as part of the Know Your Business Partner process (discussed in greater detail under Policies ).

Continuous development of ethical operations in the supply chain. The key measures in this respect include supplier commitment to the Supplier Code of Conduct in line with the 2030 sustainability targets, as well as supplier audits and assessments (discussed in greater detail under Management of relationships with suppliers ).

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Report of the Board of Directors | Metsä Board Annual review 2025

Completion of e-learning courses

2025

2024

CODE OF CONDUCT

Number of employees who completed the Code of Conduct training

1,895

2,332

Share of all employees who have completed the Code of Conduct training, %

96

99.2

Share of Board members who have completed the Code of Conduct training, %

100

DIVERSITY, EQUALITY AND INCLUSION

Number of employees who have completed DEI training

1,887

2,310

Share of all employees who have completed DEI training, %

95

98

SUSTAINABILITY

Number of employees who have completed Sustainability training

1,885

2,295

Share of all employees who have completed Sustainability training, %

95

98

Incidents of non-compliance with good governance or ethical corporate culture

2025

2024

COMPLIANCE WITH LAWS AND REGULATIONS

Significant incidents of non-compliance resulting in a fine (above EUR 10,000)

0

Significant fines paid in the reporting year for incidents that occurred in previous reporting periods (above EUR 10,000)

0

CORRUPTION OR BRIBERY CASES

Confirmed incidents of corruption or bribery

0

Confirmed incidents in which the company's own workers have been given notice or sanctioned with disciplinary measures due to an incident linked to corruption or bribery

0

Confirmed incidents in which a business agreement has been terminated or has not been renewed due to violations related to corruption or bribery

0

Public legal cases regarding corruption or bribery brought against the company and its own workers

0

Number of convictions related to anti-corruption and anti-bribery laws

0

Amount of fines for violation of anti-corruption and anti-bribery laws

0

Political influence and lobbying activities

Metsä Board participates in advocacy as part of Metsä Group at the EU and national level, especially in Finland and Sweden. Metsä Group’s parent company Metsäliitto Cooperative is registered in the EU’s Transparency Register and complies with its code of conduct. Its member number in the Transparency Register is 962687110415-94. Metsä Board is registered in the Finnish Transparency Register with the code MET-24-465-R.

The Stakeholder Engagement function is centralised at the Metsä Group level. The Stakeholder Engagement function coordinates practical influence work, handling the related cooperation among Metsä Board and other functions, and reports the work’s progress and effectiveness to Metsä Board’s and Metsä Group’s management teams and Boards of Directors. The Board of Directors of Metsä Board processes the matter as necessary. None of the members of Metsä Board’s Board of Directors,

have held public administration positions corresponding to their current positions during the last two years.

To identify the most significant legal risks and focal areas of lobbying, Metsä Group has conducted a comprehensive assessment of regulatory risks, which covers all the business areas, including Metsä Board. These risks have been considered in the double materiality assessment.

Metsä Group follows and participates in discussions about forests, biodiversity and the forest industry, and influences policy questions related to the bioeconomy and products. Metsä Group has actively influenced several legal initiatives nationally and in the EU, including the deforestation regulation, nature restoration regulation, packaging and packaging waste regulation, and sustainable product policy.

Metsä Group promotes the circular bioeconomy and emphasises the role of forests and wood-based products in climate change mitigation and the safeguarding of biodiversity. Metsä Group is committed to developing the principles of regenerative forestry, aiming to verifiably strengthen the state of forest nature in Finland by 2030. Metsä Group seeks to increase understanding of regenerative forestry and the role of renewable carbon. Statements on these themes are published on Metsä Group’s website . The company supports Finland’s national carbon neutrality target for 2035, as well as the EU’s environmental targets and the goal of climate neutrality by 2050.

Metsä Board’s advocacy efforts as part of Metsä Group focus on:

Promoting the recyclability of wood fibre-based packaging.

Increasing the understanding of the role of fresh fibre in product safety and the advantages of sustainable fibre-based food packaging in terms of the environment and health.

Supporting a comprehensive approach to laws that influence forestry practices and the availability of wood raw material as part of the joint production of forest-based ecosystem services.

Energy-related topics in the EU, such as reducing dependence on fos- sil-based fuels, focusing greater attention on the opportunities provided by biogenic carbon dioxide capture and use, and defining renewable energy targets based on something other than the direct energy use of convertible wood biomass.

Cooperation with trade and industrial organisations

As part of Metsä Group, Metsä Board is an active member of the Confed- eration of European Paper Industries (Cepi), which represents the forest industry producing fibre-based products across Europe. Representatives of Metsä Group actively participated in the work of Cepi’s committees and working groups.

A representative of Metsä Group serves as the second chair of the 4evergreen Alliance, and Metsä Board actively participates in the expert work conducted by the alliance. 4evergreen represents the entire value chain of fibre-based packaging and has set as its target the raising of the recycling rate of fibre-based packaging to 90% by 2030. Metsä Board also participates in the activities of the European Paper Packaging Alliance (EPPA). The alliance stands for the sustainability of wood fibre-based food and food service packaging and the circular economy. Metsä Board is a member of several national trade and industrial organisations.

95

Key memberships in organisations and advocacy groups:

4evergreen

Containerboard Europe

Ellen MacArthur Foundation

Confederation of European Paper Industries (Cepi)

European Association of Carton and Cartonboard manufacturers (Pro Carton)

European Carton Makers Association (ECMA)

EUROPEN – the European Organisation for Packaging and the Environment

Finnish Forest Industries Federation

Skogsindustrierna, Sweden

The European Paper Packaging Alliance (EPPA)

In 2025, Metsä Board paid EUR 1.3 (1.2) million in membership fees to trade and industrial organisations. Metsä Board does not make direct political contributions. The company may participate in seminars that deal with the forest industry or forest policy. No seminar tickets were purchased during 2025.

Reporting principles for metrics

Ethics index

The calculation of the ethics index is based on the ethics state- ments included in the annual Personnel survey. All Metsä Board employees can respond to the survey. Responses are collected on a scale of 1−4 (fully disagree/agree), and an external service provider converts the responses to indexes on a scale of 0−100 (100 = everyone fully agrees).

Share of certified wood fibre

The metric shows the share of certified wood fibre of all the wood fibre used by Metsä Board. The figure includes the wood used in Metsä Board’s own production of pulp and high-yield pulp, as well as the wood used for the pulp purchased from Metsä Fibre. The chip deliveries from the company’s own industries are not included in the calculation to avoid double counting.

Suppliers’ commitment to the Supplier Code of Conduct

The metric covers the share of purchases from suppliers that have committed to Metsä Group’s Supplier Code of Conduct or their own equivalent principles. The figure does not cover authorities, associations or wood supply.

Supplier assessments and audits of core suppliers

The metric covers the approximately 350 (350) partner, key and preferred suppliers according to the supplier classification. The target does not include wood supply operators.

Joint sustainability target with partner suppliers

The metric covers the eight partner suppliers selected in connection with Metsä Group’s supplier classification. The figure does not include wood supply, but partner suppliers include other suppliers of Metsä Group’s Wood Supply and Forest Services.

Traceability of raw materials

The target includes the raw materials used in production and product packaging materials. The target’s calculation is based on the value of the raw materials in euros. A raw material that is traceable at least to the level of country of manufacture is considered traceable.

Completion of e-learning courses

In the completion rate of the Code of Conduct, DEI and Sustain- ability e-learning courses, the divisor is the number of active employees at the time of reporting. In other words, employees absent on family leave or for other reasons are not included in the calculation.

Incidents of non-compliance with good governance or ethical corporate culture

Cases that violate legislation, good governance, the company’s Code of Conduct or policies have come to the company’s atten- tion either through the Compliance and Ethics Channel, the Know Your Business Partner process, or through contacting a member of the Compliance Committee.

Political engagement and lobbying activities

Metsä Board does not make direct donations to political purposes in cash or in kind, which is why no monetary value of in-kind benefits has been estimated.

The metrics have not been validated by an external party.

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Report of the Board of Directors | Metsä Board Annual review 2025

Annexes to the Sustainability statement

Annexes

The annexes published at the same time as the Sustainability statement include

1) Separate annexes:

SASB content index*

Disclosures in accordance with the TCFD and TNFD recommendations*

2) Data on pages 98–101 of the Sustainability statement:

Mill-specific key sustainability figures**

List of other datapoints derived from EU legislation

*TCFD and TNFD information does not come under the scope of assurance. With the exception of the share of grid electricity and the amount of energy sold, SASB data is based on Metsä Board’s Sustainability statement, which has been verified by a third party (limited assurance).

**Mill-specific figures have not been verified separately. They have been assured at com- pany level by a third party as part of the limited assurance of Metsä Board’s Sustainability statement.

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Mill-specific key sustainability figures

Mill

Joutseno

Kaskinen

Kemi

Kyro

Simpele

Tako ¹⁾

Äänekoski

Husum

Others ²⁾

Total

COUNTRY

FINLAND

SWEDEN

EMPLOYEEES

Number of employees

56

89

139

162

290

27

199

740

428

2,130

TRIF

0

7.7

8.7

8.6

16

0

3.5

4.8

LTA1F

0

7.7

4.4

8.6

14

0

3.5

4.2

PRODUCTION, 1,000 t

Paperboard

314

147

191

72

207

401

1,331

Pulp and BCTMP

191

206

550

948

MANAGEMENT SYSTEM 3)

ISO 9001

x

ISO 14001

x

ISO 50001

x

ISO 45001

x

ISO 22000

x

FSSC 22000

x

CHAIN OF CUSTODY

PEFC

x

FSC

x

EMISSIONS TO AIR, t

Biogenic carbon dioxide (CO 2 ), Scope 1

0

102,728

0

108,103

151,412

429

0

1,440,969

1,803,590

GHG emissions (CO 2 e), Scope 1

17,636

4,783

5,982

15,343

6,577

24,242

0

65,160

139,723

Sulphur (SO 2 )

0

30

0

43

49

0.01

0

32

155

Nitrogen oxides (NO x )

8.8

117

2.5

66

63

16

0

794

1,068

Particles

5.2

5.0

0

4.2

1.8

0

15

31

Total reduced sulphur (TRS)

0

26

EMISSIONS TO WATER, t

Adsorbable organic halogen (AOX)

0

40

Chemical oxygen demand (COD)

378

815

70

105

160

58

764

7,625

9,976

Biological oxygen demand (BOD)

9.5

19

14

9.6

15

13

304

377

762

Total phosphorus

0.2

1.7

0.5

0.9

0.5

15

19

Total nitrogen

2.0

10

14

12

7.0

0.05

8.1

80

134

Total suspended solids

23

75

172

29

12

113

914

1,366

WATER USE, 1,000 m³

Water withdrawals

3,494

8,492

3,947

3,679

24,015

1,419

4,067

35,853

84,965

Waste water flow

274

2,122

6,251

2,051

3,459

1,061

3,060

26,182

44,460

WASTE AND SIDE STREAMS, t

Utilised by-products and waste

6,156

17,168

558

18,355

25,302

4,661

21,271

62,650

1,432

157,553

Landfill waste

0

16

0

83

0

111

0

210

Hazardous waste

14

62

49

19

54

25

13

299

27

563

1) The Tako paperboard mill ceased operations in June 2025.

2) Includes personnel at locations other than mills and construction and demolition waste outside mill operations over which Metsä Board has operational control.

3) 100% of production units have ISO 9001, ISO 14001, ISO 50001, ISO 45001 and ISO 22000 certification. In addition, 71% have FSSC 22000 certification.

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Report of the Board of Directors | Metsä Board Annual review 2025

List of other datapoints derived from EU legislation

List of datapoints in cross-cutting and topical ESRS standards that derive from other EU legislation and their locations on the Sustainability Statement.

ESRS Disclosure Requirement and related datapoint

Location and comment

SFDR reference

Pillar 3 reference

Benchmark Regulation reference

EU Climate Law reference

ESRS 2 – General disclosures

GOV-1 Board's gender diversity

paragraph 21 (d)

The role of, information provided to and sustainability matters addressed by the administrative, management and supervisory bodies

x

GOV-1 Percentage of board members who are independent

paragraph 21 (e)

The role of, information provided to and sustainability matters addressed by the administrative, management and supervisory bodies

x

GOV-4 Statement on due diligence

paragraph 30

Due diligence process -table

x

SBM-1 Involvement in activities related to fossil fuel activities

paragraph 40 (d) i

Not material

x

SBM-1 Involvement in activities related to chemical production

paragraph 40 (d) ii

Not material

x

SBM-1 Involvement in activities related to controversial weapons

paragraph 40 (d) iii

Not material

x

SBM-1 Involvement in activities related to cultivation and production of tobacco

paragraph 40 (d) iv

Not material

x

ESRS E1 – Climate change

E1-1 Transition plan to reach climate neutrality by 2050

paragraph 14

E1 Transition plan for climate change mitigation and adaptation

x

E1-1 Undertakings excluded from Paris-aligned Benchmarks

paragraph 16 (g)

E1 Reporting principles for metrics

x

E1-4 GHG emission reduction targets

paragraph 34

E1 Metsä Group’s 2030 sustainability targets ;

E1 Transition plan for climate change mitigation and adaptation ;

E1 Reporting principles for metrics

x

E1-5 Energy consumption from fossil sources disaggregat- ed by sources (only high climate impact sectors)

paragraph 38

E1 Total energy consumption by energy source -table

x

E1-5 Energy consumption and mix

paragraph 37

E1 Energy consumption and combination of energy sources -table

x

E1-5 Energy intensity associated with activities in high climate impact sectors

paragraphs 40 to 43

E1 Energy consumption and combination of energy sources -table

x

E1-6 Gross Scope 1, 2, 3 and Total GHG emissions

paragraph 44

E1 GHG emissions -table

x

E1-6 Gross GHG emissions intensity

paragraphs 53 to 55

E1 GHG intensity -table

x

E1-7 GHG removals and carbon credits

paragraph 56

Not material

x

E1-9 Exposure of the benchmark portfolio to climate-relat- ed physical risks

paragraph 66

Not material

x

E1-9 Disaggregation of monetary amounts by acute and chronic physical risk

paragraph 66 (a)

Not material

x

E1-9 Location of significant assets at material physical risk

paragraph 66 (c)

Not material

x

E1-9 Breakdown of the carrying value of its real estate assets by energy-efficiency classes

paragraph 67 (c)

Not material

x

E1-9 Degree of exposure of the portfolio to climate-related opportunities

paragraph 69

Not material

x

ESRS E2 – Pollution

E2-4 Amount of each pollutant listed in Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil

paragraph 28

E2 Actions ;

E2 Emissions to air -table;

E2 Emissions to water -table

x

99

ESRS Disclosure Requirement and related datapoint

Location and comment

SFDR reference

Pillar 3 reference

Benchmark Regulation reference

EU Climate Law reference

ESRS E3 – Water and marine resources

E3-1 Water and marine resources

paragraph 9

E3 Policies

x

E3-1 Dedicated policy

paragraph 13

E3 Policies

x

E3-1 Sustainable oceans and seas

paragraph 14

Not material

x

E3-4 Total water recycled and reused

paragraph 28 (c)

E3 Water withdrawals and consumption and wastewa- ter discharges -table

x

E3-4 Total water consumption in m3 per net revenue on own operations

paragraph 29

E3 Water withdrawals and consumption and wastewa- ter discharges -table

x

ESRS E4 – Biodiversity and ecosystems

IRO 1 - E4

paragraph 16 (a) i

E4 The identification and assessment of material impacts, risks and opportunities

x

IRO 1 - E4

paragraph 16 (b)

E4 The identification and assessment of material impacts, risks and opportunities

x

IRO 1 - E4

paragraph 16 (c)

E4 The identification and assessment of material impacts, risks and opportunities

x

E4-2 Sustainable land / agriculture practices or policies

paragraph 24 (b)

Not material

x

E4-2 Sustainable oceans / seas practices or policies

paragraph 24 (c)

Not material

x

E4-2 Policies to address deforestation

paragraph 24 (d)

E4 Policies

x

ESRS E5 – Resource use and circular economy

E5-5 Non-recycled waste

paragraph 37 (d)

E5 Outflows of material and energy -table

x

E5-5 Hazardous waste and radioactive waste

paragraph 39

E5 Outflows of material and energy -table

Metsä Group's operations do not produce radioac- tive waste.

x

ESRS S1 – Own workforce

SBM3 - S1 Risk of incidents of forced labour

paragraph 14 (f)

x

SBM3 - S1 Risk of incidents of child labour

paragraph 14 (g)

x

S1-1 Human rights policy commitments

paragraph 20

x

S1-1 Due diligence policies on issues addressed by the fundamental International Labor Organisation Conven- tions 1 to 8

paragraph 21

x

S1-1 Processes and measures for preventing trafficking in human beings

paragraph 22

x

S1-1 Workplace accident prevention policy or management system

paragraph 23

S1 Processes to remediate negative impacts and channels for own workers to raise concerns ;

x

S1-3 Grievance/complaints handling mechanisms

paragraph 32 (c)

G1 Mechanisms for identifying, reporting and investi- gating concerns

x

S1-14 Number of fatalities and number and rate of work-related accidents

paragraph 88 (b) and (c)

S1 Health and safety -table

x

S1-14 Number of days lost to injuries, accidents, fatalities or illness

paragraph 88 (e)

S1 Health and safety -table;

The identification and assessment of material impacts, risks and opportunities (S2)

x

S1-16 Unadjusted gender pay gap

paragraph 97 (a)

S1 Total remuneration ratio of women and men -table

x

S1-16 Excessive CEO pay ratio

paragraph 97 (b)

S1 Total remuneration -table

x

S1-17 Incidents of discrimination

paragraph 103 (a)

S1 Incidents, complaints and severe human rights impacts -table

x

S1-17 Non-respect of UNGPs on Business and Human Rights and OECD

paragraph 104 (a)

S1 Incidents, complaints and severe human rights impacts -table

x

100

Report of the Board of Directors | Metsä Board Annual review 2025

ESRS Disclosure Requirement and related datapoint

Location and comment

SFDR reference

Pillar 3 reference

Benchmark Regulation reference

EU Climate Law reference

ESRS S2 – Workers in the value chain

SBM3 – S2 Significant risk of child labour or forced labour in the value chain

paragraph 11 (b)

x

S2-1 Human rights policy commitments

paragraph 17

x

S2-1 Policies related to value chain workers

paragraph 18

x

S2-1 Non-respect of UNGPs on Business and Human Rights principles and OECD guidelines

paragraph 19

x

S2-1 Due diligence policies on issues addressed by the fundamental International Labor Organisation Conven- tions 1 to 8

paragraph 19