Safety Disclosure

Process Safety Management (PSM) Disclosure

RYAM has implemented a comprehensive Process Safety Management (PSM) framework designed to prevent, detect, and mitigate process safety incidents. Our program goes beyond regulatory compliance and is structured to protect employees, contractors, communities, and the environment by ensuring disciplined execution of process safety principles across all operations.

1. Governance and Accountability

Roles and responsibilities are formally documented through the RYAM PSM Guide and site-specific organizational tools. This information is documented for the overall PSM program, the Process Hazard Analyses (PHA) process, and the Management of Change (MOC) process.
Each site maintains a PSM organizational chart that clearly defines accountability from site leadership through engineering, operations, and maintenance. The site keeps a PSM organizational chart, which is verified during PSM audits.
Leadership oversight is reinforced through regular reviews of PSM performance and integration of process safety into executive-level risk discussions. Site leadership oversight is critical during PHA/HAZOP team reviews and PSM audits. The enterprise risk management process operates above this process.

2. Training and Competency Development

RYAM ensures personnel involved in process safety activities receive required regulatory training, supplemented with annual refreshers and specialized instruction for high-risk tasks. Each facility maintains a PSM training plan that meets or exceeds regulatory requirements, outlining training needs to ensure all personnel are properly trained. During audits and PHA/HAZOP activities, training records are reviewed to verify compliance and completion. This process supports ongoing effectiveness of the PSM program.
In 2024, an enterprise-wide 8-hour virtual training series was delivered, covering all 14 PSM elements. Employees new to PSM with related roles and responsibilities are trained upon their assignments. This includes an onboarding program for managers and leaders, ensuring role-specific training in the RYAM PSM framework, expectations, and tools.

3. Risk Identification and Management

All sites conduct PHAs and Hazard and Operability Studies (HAZOPs), with updates every three years and full revalidations every 20 years.
Formal Management of Change MOC programs systematically evaluate modifications for safety impacts before approval.
These processes ensure risks are identified, assessed, and mitigated consistently across the organization.

4. Monitoring, Auditing, and Continuous Improvement

Independent third-party audits of PSM systems are conducted every five years, with findings tracked to closure in the RYAM Incident Management System (IMS).
Leading and lagging indicators are both monitored:

Leading

Elevated Monitoring Minutes (EMM), derived from stationary gas monitor data, provide near-real-time insight into releases and inform site-level and corporate decision-making.

Lagging

Incident data, audit results, and compliance metrics are centrally tracked and reviewed for trends.

Corrective actions are integrated into site and corporate objectives, ensuring sustained accountability and continuous improvement.

5. Equipment Integrity and Reliability

Sites maintain structured inspection, testing, and preventive maintenance programs within the SAP system, ensuring visibility into planned and completed work.
Ownership is clearly assigned for corrective actions, and contractor-led inspections are governed by defined scopes, technical specifications, and vendor qualification criteria.

6. Comprehensive Safety Infrastructure

RYAM’s PSM framework is underpinned by standardized corporate guidelines, site-level procedures, and digital systems such as IMS and SAP.
Core elements include:
- Detailed protocols for PHAs and HAZOPs,
- Defined vendor selection and qualification criteria,
- Standardized PSM audit protocols,
- Enterprise-wide gas monitoring and emergency response procedures.
This integrated approach ensures consistency, transparency, and alignment across all pulp mill operations.

Commitment to Leadership in Process Safety

RYAM is committed to advancing process safety performance beyond compliance. By combining rigorous governance, independent assurance, advanced monitoring, and leadership engagement, we foster a culture where process safety is integral to operational excellence.

Process & Facility Safety Management

Below are the RYAM sites covered under RYAM’s PSM framework and the last year they have been audited by a third party. Third-party audits for Jesup, Fernandina, and Tartas were performed in accordance with the RYAM Process Safety Management Protocol. The scope of the audits follows OSHA 119, Local Regulatory Requirements, and RYAM PSM & PHA Guide. These audits act as confirmation that PSM elements are standardized across all PSM plants.

Site	Audit Year
Avebene	2025
Fernandina	2024
Jesup	2024
Tartas	2024

We track several safety metrics (as will be discussed further below) and PSM related corrective actions from audit findings are entered into our corrective action system and tracked to ensure they are closed within target timeframes.

	Incidents
Completed On Time	52
In Process	3
Overdue	1
Grand Total*	56

*The safety data presented reflects a point-in-time reporting period and should be interpreted within the broader context of our ongoing performance.

Occupational Safety Performance

At RYAM, safety is a core value and a measure of operational excellence. Our structured and consistent enterprise-wide safety program has produced consistent and significant year-over-year reductions in incident rates, reflecting both our commitment and the effectiveness of our approach.

Performance Outcomes

Total Recordable Incident Rate (TRIR) has steadily declined over the past three years:

2022	2023	2024
2.66	2.27	1.52

This represents a 42% reduction in TRIR since 2022, demonstrating the sustained impact of our programs and employee engagement.

Program Structure and Leadership Commitment

Each year, we develop a Safety Roadmap informed by trends and incident learnings from the prior year. This roadmap serves as a strategic guide to drive actions that reduce injuries and enhance safe operations across all sites. It brings together our key initiatives, process improvements, and safety enhancements to ensure alignment across the organization regarding our safety direction and priorities.

Typically developed around September, the roadmap incorporates input from site teams and leadership to ensure broad engagement and relevance. It is usually structured around two to five major initiatives, with a focus on delivering key milestones on a quarterly basis throughout the following year.

Health and Safety leaders from corporate and each facility meet monthly to discuss a range of topics, including progress against the annual Safety Roadmap and key learnings from recent safety incident review calls. These incident review discussions are especially valuable, as General Managers present what occurred, the lessons learned, and the corrective actions implemented.

The purpose is not only to understand what went wrong, but to proactively share knowledge across sites assuring that similar incidents don’t occur elsewhere. Preventing repeat injuries is one of our core safety commitments as a company.

These meetings are a critical part of how we operate, learn, and continuously improve. All corrective actions are documented in our SAP-based incident management system, allowing us to track resolution with accountability and ensure timely closure.

Both of these elements form part of our broader safety structure, which includes not only the top-level Leadership Steering Committee but also cross-functional groups such as the Enterprise Risk Committee. This committee takes a critical, company-wide view to identify potential areas of weakness or emerging concerns that could elevate enterprise-level risk.

Discussions range from highly specific topics to broader, systemic issues—ensuring we remain vigilant and proactive in addressing risks. The goal is to avoid overlooking underlying cultural or systemic challenges that could compromise safety or operational integrity across the organization.

Leading Indicators and Proactive Engagement

Our program emphasizes leading safety metrics that allow us to see our actions that drive safety performance. By keeping this metrics highly visible we are able to have early identification while focusing on risks and proactive intervention, rather than relying solely on lagging indicators.

Housekeeping Score

90%

Leaders Conducting Safety Value Exchange

95%

Corrective Actions Currently On-Time

90%

Elevated Monitor Minutes

-10%

Life Safety Program Score

90%

Contractor Interactions

15%

Our Leading Safety Metrics

Leading metrics are critically important to us because we believe that every safety performance measure should be actionable—we must be able to influence it. If we are serious about preventing injuries, we must clearly understand what actions drive prevention.

We focus on six leading safety metrics, each carefully designed to influence behavior and outcomes proactively:

Housekeeping Score

Housekeeping is evaluated against 10 specific criteria tailored to the environment being assessed—whether it’s a laboratory, an office, or a pulp mill. These criteria ensure relevance to each operational area. A minimum score of 90% is expected to ensure we are maintaining conditions that help prevent incidents.

Leaders Conducting Safety Value Exchanges (SVE)

A Safety Value Exchange is a one-on-one, two-way conversation where leaders engage employees about the importance of safe behaviors, rule adherence, and understanding how to perform work safely. We expect 95% of facility leaders to conduct at least one SVE with each of their employees every month. Monthly Safety Values Exchanges between supervisors and employees foster two-way dialogue on safe practices, procedure effectiveness, and improvement opportunities. When supervisors conduct these observations of employees performing tasks against standard operating procedures, with real-time feedback and collaborative problem-solving our workplace gets safer

Corrective Actions Completed On Time

When incidents occur, we conduct thorough investigations, define corrective actions, and assign due dates. Timely completion of these actions is essential to prevent recurrence. We closely monitor and track adherence to deadlines, with a performance expectation of 90% or greater.

Elevated Monitor Minutes

This metric captures the total number of minutes our gas detection monitors are in an elevated or alarm state. For example, if one monitor alarms for 10 minutes, it contributes 10 minutes to this metric. Each year, we set a reduction target (e.g., 15%) to continuously improve air quality and reduce exposure risks. This has proven to be highly effective in enhancing our work environment.

Life Safety Program (LSP) Score

Life Safety Programs address our most critical and high-risk activities—such as lockout/tagout and confined space entry. We assess each of the six LSPs against best-in-class standards, focusing not just on the presence of a program, but on the quality of implementation, training, and operational integration. The target performance is a 90% score or above.

Contractor Interactions

With this new introduction to our LSP suite, we actively engage with contractors through safety discussions, inspections, audits, and evaluations during their time on site. This metric measures the percentage of contractors and contractor employees who receive this interaction, relative to the total number of contractor personnel present. This is a new way of measuring ourselves. Our new performance expectation is 15%, with a continued focus on improvement as we mature in this area.

These six leading indicators reflect our commitment to proactive safety management. They give us clear visibility into the behaviors, systems, and conditions that impact safety every day—and ensure that we are consistently taking meaningful actions to protect our people and those that work in our plant.

Each year we look at our leading safety metrics and challenge the status quo to ensure we are measuring the right things. Over the past 2 years we have raised the difficulty of the “best in class” set of questions to ensure we work towards the highest standards. As we have made our leading metrics more difficult to achieve with these resets we move from the mid-30s to 95% in some cases. This challenges our sites to work very hard to maintain the high percentages as a stable trend. Failure to meet the targets shown above for the safety-related KPIs would have a direct impact on 10% of the overall management incentives.

Culture of Learning and Continuous Improvement

Safety Incidents with High Learnings—whether a near miss, first aid, or more serious—is reviewed for lessons learned.

High-value learnings are shared through monthly incident review calls where general managers present investigation findings to all facilities, ensuring best practices are widely adopted and repeat incidents prevented.

Successes are celebrated through company-wide safety days, housekeeping competitions, and recognition of exemplary safety practices, reinforcing positive behaviors and building engagement.

Commitment to Employees and Contractors

The same safety expectations and programs apply equally to employees and contractors, ensuring a consistent culture of safety across our operations.

Leading metrics and proactive engagement practices directly influence the safe behaviors and conditions that protect everyone in our workplaces.

Conclusion

RYAM’s declining incident rates, combined with strong governance, proactive leading indicators, and active cultural engagement at every level, demonstrate our commitment to achieving a zero-injury workplace. We will continue to build on this foundation to further advance our safety performance.

Employee Safety Performance (Incidence Rates)

	Number of Recordable Incidents	Total Recordable Incidence Rate	Lost Time Incidence Rate	DART rate
2022	74	2.66	1.94	86.81
2023	62	2.27	1.73	91.71
2024	40	1.52	1.06	52.39

Employee and Contractor Fatalities

At RYAM, nothing is more important than ensuring every person—employee or contractor—returns home safely at the end of the day. While we have made significant progress in reducing workplace incidents and building a culture of safety, we recognize that any fatality is unacceptable and a solemn reminder of the responsibility we hold.

We do not frame zero fatalities as a goal — it is a moral imperative. The loss of life is never acceptable, and we do not treat it as a target to strive toward, but as a fundamental expectation. Every individual has the right to go home safely, and we are fully committed to eliminating fatal risks through our systems, culture, and leadership.

Conclusion

Employee Fatalities

Our last employee fatality occurred in 2018 at a sawmill in Canada (since divested).

Following this tragic event, RYAM conducted a comprehensive investigation and implemented enhanced safeguards across operations, including strengthened Powered Industrial Vehicle procedures, targeted training, and independent safety audits to prevent recurrence.

Contractor Fatalities

Our most recent contractor fatality occurred in 2023 at our Tartas, France facility during a confined space entry.

This incident was deeply reviewed in collaboration with local authorities and independent experts. Immediate corrective actions included:

Strengthened confined space entry protocols, including enhanced permit-to-work requirements and atmospheric testing.
Expanded training for both employees and contractors on high-risk tasks.
Additional monitoring and auditing of contractor-led activities.

These lessons learned were shared across all RYAM sites through our global incident review process to ensure preventive measures are universally applied.

Commitment and Continuous Improvement

Since 2019, we have had no employee fatalities, and our goal remains to eliminate serious incidents across all operations.

Contractor safety is fully integrated into our health and safety management system. Contractors receive the same level of oversight and expectations. We provide training opportunities and have implemented a best-in-class contractor management system.

We partner with a third-party service to collect and review critical safety documentation from all contracting companies, including safety performance metrics and workers’ compensation data. This vetting process ensures that we engage only those companies that align with our safety standards and have the capability to operate within our safety culture.

As part of this process, each contracting company must receive formal approval before being permitted to work on our sites. Additionally, every contractor employee is required to complete a comprehensive safety orientation before gaining access. This strict system ensures that no individual is allowed on site without the appropriate safety credentials, reinforcing our commitment to maintaining a safe work environment.

RYAM leadership regularly reviews serious incident trends and fatality-prevention initiatives to ensure that learnings drive lasting improvements.

As we have stated previously, we do not frame zero fatalities as a goal; it is a moral imperative and that applies to contractors as well. We work hard to continue to strengthen our safety culture, systems, and monitoring to advance contractor safety.

Transparency and Accountability

We believe that transparent disclosure of fatalities—alongside the actions taken to address root causes—is an essential part of building trust with employees, contractors, communities, and stakeholders. RYAM is committed to sharing both our progress and our challenges as we strive for world-class safety performance.

Safety System Certifications and Assurance

At RYAM, we are committed to ensuring that our safety management systems operate at the highest international standards of rigor and effectiveness. While certification can serve as one measure of performance, we believe that true excellence comes from consistent practices, strong governance, and continuous improvement across all of our facilities.

Certifications at Our Facilities

Our Témiscaming, Quebec and Tartas, France facilities currently hold ISO 9001 (Quality Management) and ISO 14001 (Environmental Management) These certifications reflect our disciplined approach to global standards and our commitment to meeting customer expectations.

Our Tartas, France facility is certified to ISO 45001 (Occupational Health & Safety Management), their safety management systems are fully aligned with ISO 45001 principles. This certification validates that our safety management systems meet rigorous external criteria and that our facility undergoes independent surveillance audits and full recertification cycles to maintain compliance.

Alignment Across All Operations

RYAM Safety Management Systems Alignment with ISO 45001

All facilities operate systems that meet or exceed key ISO 45001 elements, though formal certification has not been pursued due to market focus on quality and environmental standards.

Context of the Organization

Clear understanding of internal/external safety risks and opportunities
Enterprise Risk Committee reviews system-wide safety and operational risks
Leadership-level oversight through the Safety Steering Committee

Leadership & Worker Participation

Active involvement of senior leadership in safety performance and improvement
Monthly safety calls with General Managers to share learnings and corrective actions
Site-level employee engagement through Safety Value Exchanges (SVEs) and participation in incident reviews

Planning

Annual, enterprise-wide Safety Roadmap developed from trends and incident learnings
Focused on 2–5 major initiatives with quarterly deliverables
Risk assessments conducted as part of ongoing operations and change management

Support

Comprehensive contractor prequalification and orientation process
Leading metrics system in place (e.g., housekeeping, corrective actions, Life Safety Programs)
Robust training programs tailored to role and risk level
Third-party tools support contractor compliance and data integrity

Operational Control

Life Safety Programs (e.g., Lockout/Tagout, Confined Space) deployed at all sites
Site-specific safety procedures and controls tailored to operations
No site access permitted without proper training and credentials
Corrective actions tracked and managed in SAP-based incident management system

Performance Evaluation

Leading and lagging metrics tracked across all facilities
Elevated monitor minutes tracked and targeted for continuous improvement
Monthly facility reviews of injury data, trends, and shared learnings
Internal audits and inspections regularly conducted to verify control effectiveness

Improvement

Culture of continuous improvement rooted in proactive risk identification
Incident reviews and cross-facility knowledge sharing to prevent recurrence
Systematic tracking of corrective actions through closure
Annual review and revision of safety programs based on learnings and performance

Safety is integrated into our enterprise management system alongside quality and environmental performance, reflecting our commitment to a holistic approach to operational excellence.

Audit and Assurance Practices

Every facility undergoes a three-year audit cycle and we use a combination of corporate-led and independent third-party reviews covering compliance with:

Country and Local regulatory compliance requirements,
Corporate safety standards (e.g., chemical management, etc.), and
Internationally recognized process safety management (PSM) principles.

We require that related corrective actions be entered into a tracking system to ensure timely closure of issues ensuring robust assurance and accountability.

SITE	Task Overdue Count	Tasks In Process On Time Count	% In Process On Time
Wood Procurement, USA	0	4	100%
Témiscaming, CAN	1	32	97%
Tartas, FR	4	26	87%
RCC – Temiscaming, CAN	0	0	No Actions
MRC – Jesup, GA, USA	0	1	100%
Jesup, GA, USA	0	16	100%
Gradignan, FR	0	0	No Actions
Fernandina Beach, FL, USA	0	10	100%
Avébène, FR	5	2	29%
Total	10	91	90%*

*The safety data presented reflects a point-in-time reporting period and should be interpreted within the broader context of our ongoing performance.

Commitment to Continuous Improvement

RYAM maintains a cycle of learning and improvement. Audit findings, incident reviews, and best practices are shared across facilities. The information that is gathered during these audits is integrated into our annual safety roadmap.

Recognition of Excellence

We are proud of the achievements at our Tartas facility, which continues to uphold ISO certification through disciplined implementation and successful recertification. At the same time, we salute the commitment of all facilities that operate to similar high standards, regardless of formal certification. Together, these systems demonstrate that safety is not just a compliance obligation at RYAM—it is a deeply embedded value and an essential driver of operational excellence.

Commitment to Continuous Improvement

Recognition of Excellence

Certification of Health & Safety Management Systems

	Context of the Organization	Leadership & Worker Participation	Planning	Support	Operational Control	Performance Evaluation	Improvement
Tartas, France	ISO 45001 certification	ISO 45001 certification	ISO 45001 certification	ISO 45001 certification	ISO 45001 certification	ISO 45001 certification	ISO 45001 certification
Jesup, GA, USA	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent
Fernandina Beach, FL, USA	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent
Temiscaming, QB, CA	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent	ISO 45001 Equivalent

Contractor Safety and Incidence Rates

At RYAM, the health and safety of contractors are treated with the same rigor and commitment as that of our employees. Contractors are integral to our operations, and ensuring their safety is central to our culture of operational excellence.

Tracking and Measuring Contractor Safety Performance

For many years, RYAM has recorded all contractor recordable injuries.

Beginning in 2025, we enhanced this process by systematically collecting contractor hours worked, captured through our digital access system when contractors scan in and out of facilities.

This development enables us to calculate a Contractor Total Recordable Incident Rate (TRIR) with the same precision and consistency as our employee TRIR.

Contractor TRIR is now calculated alongside employee TRIR and displayed on our internal safety performance dashboard, ensuring visibility, accountability, and ongoing performance management.

To validate this new data set, RYAM is dedicating 2025 to data accuracy verification before fully adopting the metric into external reporting.

Leading Metrics for Contractor Safety

RYAM’s approach goes beyond tracking lagging indicators. We have established a suite of leading contractor safety metrics designed to drive behavior, prevent incidents, and improve accountability:

Inspections of contractor employees – calculated as the percentage of contractor workers observed in safety inspections (e.g., if 2 of 10 employees are inspected, 20% are covered).
Audits of high-risk safety programs – such as confined space entry or lockout/tagout, measured as the percentage of contractor companies audited versus the number active on site.
End-of-job performance evaluations – covering five key dimensions including safety, timeliness, cost, and quality. Evaluations are tracked as the percentage of contractor companies assessed relative to those engaged.

These leading metrics provide early insight into contractor performance and allow RYAM to take corrective action before incidents occur. They are directly linked to our contractor management process and form part of our continuous improvement cycle.

Integration and Accountability

Contractor safety performance is reviewed by site-level safety committees and escalated to corporate leadership for oversight.
Metrics and findings from inspections, audits, and evaluations are used to inform contractor selection, renewal decisions, and future work opportunities.
Contractors are expected to actively participate in safety programs, and feedback from job evaluations is shared directly with contractor leadership to drive improvements.

The first year that contractor TRIR will be valid for external reporting will be 2026. This same validation process is applied to our leading metrics for contractor safety. While we closely manage contractor safety the use of formal metrics will go into effect in 2026. All contractor recordable injuries and RYAM’s corrective actions are tracked in IMS/SAP.

Commitment to Continuous Improvement

By aligning contractor safety reporting with employee reporting and strengthening our leading metrics, RYAM is ensuring contractors are fully integrated into our safety culture. Our goal is to establish transparent, reliable contractor safety data that not only reflects past performance but also drives future improvements.

We are proud of the progress made to date and remain committed to reducing contractor incident rates through a disciplined, data-driven, and collaborative approach.