This is a translation of the Independent Auditor’s Report originally issued in Polish
INDEPENDENT AUDITOR’S REPORT
To the General Meeting and the Supervisory Board of Bank Millennium S.A.
Report on the Audit of the Annual Consolidated Financial Statements
Opinion
We have audited the annual consolidated financial statements of the group (the “Group”) with Bank
Millennium S.A. as the parent (the “Parent”, “Bank”), which comprise the consolidated statement of financial
position as at December 31, 2022, and the consolidated income statement, consolidated statement
of total comprehensive income, consolidated statement of changes in equity and consolidated cash flow
statement for the year then ended, and notes to the consolidated financial statements, including a summary
of significant accounting policies and other explanatory information (the “consolidated financial statements”).
In our opinion, the accompanying consolidated financial statements:
give a true and fair view of the economic and financial position of the Group as at December 31, 2022,
and of its financial performance and its cash flows for the year then ended in accordance with the applicable
International Financial Reporting Standards, as endorsed by the European Union, and the adopted
accounting policies;
comply, as regards their form and content, with the applicable laws and the articles of association
of the Parent.
Our opinion is consistent with the Additional Report to the Audit Committee which we issued on date
of this report.
Basis for Opinion
We conducted our audit in accordance with the Polish Standards on Auditing (“PSAs”) in the wording
of the International Standards on Auditing adopted by the National Council of Statutory Auditors
and in compliance with the Act on Statutory Auditors, Audit Firms and Public Oversight of 11 May 2017
(the “Act on Statutory Auditors”, Journal of Laws of 2022, item 1302, as amended) as well as Regulation (EU)
No 537/2014 of the European Parliament and of the Council of 16 April 2014 on specific requirements regarding
statutory audit of public-interest entities (“EU Regulation”, Official Journal of the European Union L158,
as amended). Our responsibilities under those standards are further described in the Auditor’s Responsibilities for
the Audit of the Consolidated Financial Statements section of our report.
We are independent of the Group in accordance with the principles of professional ethics specified
in the International Code of Ethics for Professional Accountants (including International Independence Standards)
(“Code of ethics”) developed and issued by the International Ethics Standards Board for Accountants and adopted
by the National Council of Statutory Auditors, together with the ethical requirements that are relevant to the audit
of the financial statements in Poland, and we have fulfilled our other ethical responsibilities in accordance with
these requirements and the Code of ethics. Throughout the audit, both the key statutory auditor and the audit
firm remained independent of the Group in accordance with the independence requirements set out in the Act
on Statutory Auditors and in the EU Regulation.
We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our
opinion.
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Emphasis of Matter
Please note the disclosure in section 13.2 of the consolidated financial statements, in which the Management
Board of the Bank provided relevant information on the pending decision of the Civil Chamber of the Supreme
Court and the Court of Justice of the European Union, which may have an impact on the current status of disputes
concerning mortgage loans indexed to Swiss franc (CHF) and the alternative settlement solution currently being
applied to the above-mentioned loans. Our opinion is not qualified in respect of this matter.
Key Audit Matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit
of the consolidated financial statements of the current period. They encompass the most significant assessed
risks of material misstatement, including assessed risks of material misstatement due to fraud. These matters
were addressed in the context of our audit of the consolidated financial statements as a whole, and in forming
our opinion thereon. We summarized our response to those risks and, where appropriate, we presented the key
findings related to those risks. We do not provide a separate opinion on these matters.
Key audit matter
How we addressed the matter
Provisions for litigations concerning the portfolio of mortgage loans indexed to Swiss franc (CHF)
The Parent has granted foreign currency
mortgage loans indexed to CHF ("CHF loans").
As it is presented in the Note 14.22j
of the consolidated financial statement Loans
and advances to customers the gross value
of CHF loans deducted by the change
of expected cash flows resulting from legal risk,
amounted to approx. 7 billion
as of 31 December 2022. As it is described
in the Note 13.1 of the consolidated financial
statements Court claims and current provisions
on legal risk, the Parent is a defendant in
numerous legal cases which include claims
regarding the partial invalidity of the credit
agreements, i.e. in terms of indexation
provisions or a ruling that the agreements are
fully invalid.
Management's judgments regarding
the recognition and measurement of provisions
for legal cases are inherently burdened with risk
and may change in the future due to the fact
that the estimated results of the current cases
depend on future resolutions.
It should be noted that the judgement
of the European Union Court of Justice from
3 October 2019 regarding CHF loans increases
the uncertainty of estimates of the essential
provisions.
In addition, further expected decisions
of the European Union Court of Justice
(regarding the legitimacy of including by banks
the remuneration for cost of capital) may affect
amount of necessary provisions.
Our procedures included, among the others:
understanding of the process and controls of the Parent
towards creation of individual provisions on CHF loans
legal cases and review of the mentioned process and
controls with regard to the model applied for the
estimation of the provision for CHF loans portfolio;
verification of the methodology of estimating provisions
with regard to the legal proceedings and proposed
settlements related to loans indexed to CHF and the
analysis of the rationality and validity of the adopted
assumptions as well as the correctness of the input data
and the calculation of the provisions estimates, including
especially:
-
the probability of assumed scenarios and the
occurrence of the particular types of verdicts for
pending and future legal cases;
-
the estimated amount of losses in the event of the
each type of verdict and the proposed settlements;
-
the estimated inflow of new individual claims and
estimated number of settlements and their
distribution over the time;
verification of the list of claims in which the Parent is a
defendant and verification of the opinions of the external
lawyers including verification of independent
confirmations from external law firms;
assessment of the adequacy and the completeness of
provisions for the legal cases identified by the Parent with
regard to the existing legal documentation, and analysis of
the provision sensitivity to the changes in the most
important assumptions;
we performed review of the current and expected
jurisdiction in case of CHF loans claims;
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Key audit matter
How we addressed the matter
Due to the materiality of the CHF loan portfolio,
as well as the significant role and complexity of
the Management Board's judgments and
estimates regarding provisions for the current
and potential claims and the proposed
settlements, the recognition and the valuation
of the mentioned provision was considered
as the key audit matter.
analysis of the significant data after the balance sheet
date in relation to the assumptions adopted by the Parent
as at the balance sheet date;
analysis of the accuracy and completeness of disclosures
in the consolidated financial statements in this respect.
Impairment of loans and borrowings granted to customers
Detailed information on the methods and
models applied by the Group and the level
of impairment losses on loans and advances to
customers is presented in point 7.3 Adopted
accounting principles, point 8.3 Credit risk
and Note 14.22 Loans and advances to
customers in the consolidated financial
statements.
This matter was considered by Deloitte to be
the key audit matter due to the significant
impact of impairment allowances on valuation
of credit receivables as well as due to the fact
that they require a significant judgement
of the Parent's Management Board and
adoption of significant assumptions
in the process of their estimation, including
the adopted macroeconomic estimates,
especially with regard to the estimation
of credit risk parameters in models of expected
credit losses calculation in accordance with
the requirements of the International Financial
Reporting Standard 9 "Financial Instruments"
(IFRS 9).
We have critically analyzed the design and implementation
of the process and policy of calculation of the impairment
allowances on credit exposures and we have assessed
the control system in this process, including automated
controls in the Group's IT systems, considering also possible
omission of controls.
Our audit procedures included reconciliation of the loan
database with the general ledger of the Group to confirm
the completeness of the recognition of credit receivables that
are the basis for impairment losses calculation, as well
as the value of these impairment allowances on loans.
With regard to the verification of the correct application
of the requirements of IFRS 9, our procedures included,
among the others:
evaluation of the methodology applied by the Group with
respect to the classification and valuation of financial
assets in terms of their compliance with the requirements
of IFRS 9 and with the market practice;
evaluation of the Group's impairment methodology from
the perspective of compliance with the requirements
of IFRS 9, in particular as regards the application of SICR
criteria, which means a significant increase in credit risk
from the moment of granting a loan, for a selected
sample of loan exposures, definition of default, adopted
PD and LGD parameters and taking into account
prospective information in the calculation of expected
credit losses;
assessment of the completeness and correctness
of the disclosures, especially as regards the credit risk
of financial assets.
For the collectively assessed loans, we have performed,
among the others, the following procedures:
analysis of the applied methodology of estimating
allowances for expected credit losses, including adequacy
of risk parameters used by the Group;
independent recalculation of the expected loss
allowances for randomly selected exposures and chosen
parameters in the portfolio approach;
evaluation of changes in the assumptions made for
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Key audit matter
How we addressed the matter
the construction of models used for the measurement
of credit risk and the applied approach to the verification
of models based on historical data (so-called "back-
tests").
With regard to the impairment estimated on the basis
of the individual method we have performed the following
procedures:
analysis of the correctness of the process of identifying
the triggers for impairment;
assessment of the correctness of the estimation of write-
offs for the selected sample of the credit exposures with
identified evidence of the impairment in terms
of the correctness of the assumed values of collaterals
and assumptions concerning other cash flows.
Revenue recognition of interest income and fee and commission income
Interest income and fee and commission
income are presented in detail in Note
14.1 Interest income and other of similar nature
and Note 14.3 Fee and commission income
and expenses in the consolidated financial
statements.
We assess this as key audit matter due to
the share of interest and commission income
in the Group's total income and the fact that
they are the key elements of the Group's
profitability assessment.
Our procedures included, among the others:
analysis of the internal control environment in terms
of the recognition and presentation of the interest
income and the fee and commission income;
review of the accounting policy of the Group with regard
to the revenue recognition and assessment of the rules
for determining the effective interest rate on interest
income on loans, including automatic controls in the IT
systems of the Group;
analysis of trends in interest and commission income
recognition, including explanation of unusual events and
one-off transactions;
detailed verification of revenues recognized as one-off;
evaluation of the existence and valuation of revenues
based on a sample of transactions.
Assessment of the going concern assumption
In accordance with International Standard
on Auditing 570, the auditor shall evaluate
management’s assessment of the entity’s ability
to continue as a going concern.
As it is described in point 7.1 Statement of
compliance with International Financial
Reporting Standards of the consolidated
financial statements, the financial statements
were prepared with going concern assumption
which assumes continuation of the Parent’s
operations for at least 12 months from the date
of financial statements.
Due to the introduction of so-called credit
holidays for 2022 and 2023 years the Group
has incurred a financial loss. The recognition
International Standard on Auditing 570 requires a number
of audit procedures that we performed in response to
the Parent's implementation of the Recovery Plan and
the Capital Protection Plan:
review of the Parent's Recovery Plan and Capital
Protection Plan;
discussion with the Parent’s Management Board
regarding plans and actions to be taken to secure
the continuation of the Parents's and Group’s operations
and realization of the Parent's Recovery Plan and Capital
Protection Plan;
assessment of the feasibility of realization of the above-
mentioned plans by the Parent;
discussion with management and analysis of potential
impact of the future materialization of uncertainties
including risks related to possible extension of so-called
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Key audit matter
How we addressed the matter
of the costs of so-called credit holidays resulted
in a temporary deterioration of capital ratios
which caused a necessity of launching
of the Recovery Plan (which together with
the Capital Protection Plan is currently being
realized by the Parent). After execution of plans
approved by the Polish Financial Supervision
Authority the capital ratios as at 31 December
2022 are above the minimal requirements.
However, as presented in point 8.2 Capital
management of the consolidated financial
statements the Parent is required to comply
with additional capital requirements. Lack
of meeting capital requirements by the Parent
may trigger regulatory actions and impact
continuance of the Parent’s and Group’s
operations.
credit holidays and an unfavorable development
of jurisdiction line in relation FX mortgage loans;
review of the capital adequacy ratios together with
a sensitivity analysis in the event of negative scenarios;
review of the Parent’s liquidity position;
review of relevant minutes and correspondence with
regulator in this regard;
analysis of the disclosure in the consolidated financial
statements regarding the adoption of the going concern
principle.
Responsibilities of the Management Board and the Supervisory Board of the Parent for the Consolidated Financial
Statements
The Parent’s Management Board is responsible for the preparation of consolidated financial statements which
give a true and fair view of the economic and financial position of the Group and of its financial performance
in accordance with the applicable International Financial Reporting Standards, as endorsed by the European
Union, the adopted accounting policies as well as the applicable laws and articles of association of the Parent,
and for such internal control as the Parent’s Management Board determines is necessary to enable
the preparation of consolidated financial statements that are free from material misstatement, whether due to
fraud or error.
In preparing the consolidated financial statements, the Parent’s Management Board is responsible for assessing
the Group’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and
using the going concern basis of accounting unless the Parent’s Management Board either intends to liquidate
the Group or to cease operations, or has no realistic alternative but to do so.
The Management Board and members of the Supervisory Board of the Parent are obliged to ensure that
the consolidated financial statements meet the requirements of the Accounting Act of 29 September 1994
(the “Accounting Act”, Journal of Laws of 2023, item 120). Members of the Parent’s Supervisory Board are
responsible for overseeing the financial reporting process.
Auditor’s Responsibilities for the Audit of the Consolidated Financial Statements
Our objectives are to obtain reasonable assurance about whether the consolidated financial statements
as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report
that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit
conducted in accordance with PSAs will always detect a material misstatement when it exists. Misstatements can
arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be
expected to influence the economic decisions of users taken on the basis of these consolidated financial
statements.
The scope of an audit does not include an assurance about the future profitability of the Group
or the effectiveness or efficiency of the Parent’s Management Board in managing the Group’s affairs at present
or in the future.
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As part of an audit in accordance with PSAs, we exercise professional judgment and maintain professional
skepticism throughout the audit. We also:
identify and assess the risks of material misstatement of the consolidated financial statements, whether
due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit
evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting
a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve
collusion, forgery, intentional omissions, misrepresentations, or the override of internal control;
obtain an understanding of internal control relevant to the audit in order to design audit procedures
that are appropriate in the circumstances, but not for the purpose of expressing an opinion
on the effectiveness of the Group’s internal control;
evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates
and related disclosures made by the Parent’s Management Board;
conclude on the appropriateness of the Parent’s Management Board’s use of the going concern basis
of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to
events or conditions that may cast significant doubt on the Group’s ability to continue as a going concern.
If we conclude that a material uncertainty exists, we are required to draw attention in our auditor’s report
to the related disclosures in the consolidated financial statements or, if such disclosures are inadequate,
to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date
of our auditor’s report. However, future events or conditions may cause the Group to cease to continue
as a going concern;
evaluate the overall presentation, structure and content of the consolidated financial statements,
including the disclosures, and whether the consolidated financial statements represent the underlying
transactions and events in a manner that achieves fair presentation;
obtain sufficient appropriate audit evidence regarding the financial information of the entities or business
activities within the Group to express an opinion on the consolidated financial statements. We are
responsible for the direction, supervision and performance of the Group audit. We remain solely responsible
for our audit opinion.
We communicate with the Parent’s Supervisory Board regarding, among other matters, the planned scope and
timing of the audit and significant audit findings, including any significant deficiencies in internal control that we
identify during our audit.
We also provide the Parent’s Supervisory Board with a statement that we have complied with relevant ethical
requirements regarding independence, and that we will communicate with it all relationships and other matters
that may reasonably be thought to bear on our independence, and where applicable, related safeguards.
From the matters communicated with the Parent’s Supervisory Board, we determined those matters that were
of most significance in the audit of the consolidated financial statements of the current period and are therefore
the key audit matters. We describe these matters in our auditor’s report unless law or regulation precludes public
disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be
communicated in our report because the adverse consequences of doing so would reasonably be expected to
outweigh the public interest benefits of such communication.
Other Information, Including the Report on the Activities
Other information includes a report on the Group’s activities in the financial year ended December 31, 2022
(the “Report on the Activities”), together with a statement of compliance with corporate governance principles
and a non-financial information statement, as referred to in Article 49b.1 of the Accounting Act, which constitute
separate parts of the Report (together: the “Other Information”).
The Report on the activities of the Bank Millennium Group and the Bank for 2022, in accordance with Article
55(2a) of the Accounting Act, has been prepared jointly.
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Responsibilities of the Management Board and the Supervisory Board
The Parent’s Management Board is responsible for the preparation of the Other Information in accordance with
the applicable laws.
The Management Board and members of the Supervisory Board of the Parent are obliged to ensure that
the Report on the Activities, along with the separate parts, meet the requirements of the Accounting Act.
Auditor’s Responsibilities
Our opinion on the consolidated financial statements does not cover the Other Information. In connection with
our audit of the consolidated financial statements, our responsibility is to read the Other Information and, in doing
so, consider whether the Other Information is materially inconsistent with the consolidated financial statements
or our knowledge obtained in the audit or otherwise appears to be materially misstated. If, based on the work we
have performed, we conclude that there is a material misstatement of this Other Information, we are required to
report that fact in our auditor’s report. Additionally, under the Act on Statutory Auditors we are obliged to express
an opinion on whether the Report on the Activities has been prepared in accordance with the applicable laws and
whether it is consistent with the information contained in the consolidated financial statements. Furthermore,
we are obliged to state whether a non-financial information statement has been prepared by the Group and to
express an opinion on whether the Group has included the necessary information in the statement of compliance
with corporate governance principles.
Opinion on the Report on the Activities
Based on our work performed during the audit, we are of the opinion that the Report on the Activities:
has been prepared in accordance with Article 49 of the Accounting Act and par. 71 of the Regulation
of the Minister of Finance of 29 March 2018 on current and periodic information published by issuers
of securities and the rules of equal treatment of the information required by the laws of non-member states
(the “Current Information Regulation”, Journal of Laws of 2018, item 757, as amended);
is consistent with the information contained in the consolidated financial statements.
Furthermore, in the light of the knowledge and understanding of the Group and its environment obtained
in the course of the audit, we have not identified any material misstatements of the Report on the Activities.
Opinion on the Statement of Compliance with Corporate Governance Principles
In our opinion, the statement of compliance with corporate governance principles contains the information
referred to in par. 70.6.5 of the Current Information Regulation. We are also of the opinion that the information
referred to in par. 70.6.5(c)-(f), (h) and (i) of the Regulation, as contained in the statement of compliance with
corporate governance principles, is in accordance with the applicable laws and consistent with the information
included in the consolidated financial statements.
Information on Non-Financial Information
In accordance with the requirements of the Act on Statutory Auditors, we would like to inform you that the Group
prepared a separate report on non-financial information and included this information in the Report
on the Activities, and also attached this report to the annual consolidated financial statements of the Group.
By the date of this audit report, the Group had published report on non-financial information on its website.
We have not performed any assurance services relating to the separate non-financial information statement and
we do not express any form of assurance conclusion thereon.
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Report on Other Legal and Regulatory Requirements
Opinion of an independent auditor on the performance of an attestation service for verifying the conformity
of consolidated financial statements drawn up in a single electronic reporting format with the requirements
of the Technical Standards Regulation concerning the specifications of the single electronic reporting format
Subject matter of the service
In connection with the audit of the consolidated financial statements, we conducted an attestation service
providing reasonable assurance as to the assessment, whether the Group's consolidated accounts for the year
ended 31 December 2022 prepared in a single electronic reporting format contained in a file named
groupamillennium-2022-12-31-pl.zip ('consolidated financial statements in ESEF format') have been drawn up
in accordance with the requirements set out in Commission Delegated Regulation (EU) 2019/815 of 17 December
2018 supplementing Directive 2004/109/EC of the European Parliament and of the Council with regard to
regulatory technical standards for the specification of the single electronic reporting format ("ESEF Regulation").
Identification of criteria
The consolidated financial statements in ESEF format have been prepared by the parent company's management
to comply with the labeling and technical requirements for the specifications of the uniform electronic reporting
format that are set out in the ESEF Regulation.
The object of our assurance service is the compliance of the labeling of the consolidated financial statements
in ESEF format with the requirements of the ESEF Regulation, and the requirements set forth in those regulations
are, in our opinion, appropriate criteria for forming our opinion.
Responsibility of the Management Board and the Supervisory Board of the Parent
The Management Board is responsible for the preparation of the consolidated financial statements in ESEF format
in accordance with the labeling requirements and technical requirements for the Uniform Electronic Reporting
Format specifications set forth in the ESEF Regulation. This responsibility includes the selection and application
of appropriate XBRL tags, using the taxonomy specified in the ESEF Regulation.
The responsibility of the Management Board shall also include the design, implementation and maintenance
of an internal control system ensuring that consolidated financial statements are drawn up in an ESEF format free
from material non-compliance with the requirements of the ESEF Regulation.
The members of the Parent Company's Supervisory Board are responsible for overseeing the financial reporting
process, which includes the preparation of consolidated financial statements in accordance with the format
prescribed by applicable laws.
Auditor's responsibilities
Our objective was to express an opinion, on the basis of the assurance service performed, that provides
reasonable assurance whether the consolidated financial statements of the Group for the year ended
31 December 2022 have been labelled in accordance with the requirements of the ESEF Regulation.
We conducted this service in accordance with the National Standard on Assurance Engagements Other than Audit
and Review 3001PL - "Audit of Financial Statements Prepared in Uniform Electronic Reporting Format" adopted
by the National Council of Statutory Auditors (hereinafter: "KSUA 3001PL") and, where applicable, in accordance
with the National Standard on Assurance Engagements Other than Audit and Review 3000 (Z) as set forth
in International Standard on Assurance Engagements 3000 (Revised) - "Assurance Engagements Other than Audits
or Reviews of Historical Financial Information" (hereinafter: "KSUA 3000 (Z)").
This standard requires the auditor to plan and perform procedures to obtain reasonable assurance that
the consolidated financial statements in ESEF format have been prepared in accordance with specified criteria.
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Reasonable assurance is a high level of assurance but does not guarantee that a service performed in accordance
with KSUA 3001PL and, where applicable, in accordance with KSUA 3000 (Z), will always detect an existing material
misstatement.
The selection of procedures depends on the auditor's judgment, including his or her assessment of the risks
of material misstatement due to fraud or error. In making those risk assessments, the auditor considers internal
control relevant to the preparation of the consolidated financial statements in ESEF format to design appropriate
procedures to provide the auditor with sufficient and appropriate evidence in the circumstances. An assessment
of the operation of the internal control system has not been made for the purpose of expressing an opinion
on its effectiveness.
Quality control requirements
We apply the National Quality Control Standards adopted by the National Board of Auditors in the version
of the International Standard on Quality Control 1 "Quality Control of companies conducting audits and reviews
of financial statements and other attestation and related services" and in accordance with it we maintain
a comprehensive quality control system including documented policies and procedures regarding compliance
with ethical requirements, professional standards and applicable legal and regulatory requirements.
Ethical requirements and independence
In performing our services, both as an audit firm and as a statutory auditor, we comply with the independence
and other ethical requirements set out in the Code of Ethics. The Code of Ethics is based on the fundamental
principles of integrity, objectivity, professional competence and due care, confidentiality and professional
conduct. We have also complied with other independence and ethical requirements that are applicable to
this assurance service in Poland.
Summary of the work performed
The procedures we planned and carried out included, among others:
understanding of the process for preparing consolidated financial statements in ESEF format, including
the Company's process for selecting and applying XBRL tags and ensuring compliance with the ESEF
Regulation, including an understanding of the internal control system mechanisms related to this process;
reconciliation of the labeled (on a selected sample) information contained in the consolidated financial
statements in ESEF format to the audited consolidated financial statements;
using a specialized IT tool to assess compliance with the technical standards for the Single Electronic
Reporting Format specification, to assess the completeness of tagging the information in the consolidated
financial statements in ESEF format with XBRL tags;
assessing whether the applied XBRL tags from the taxonomy defined in the ESEF Regulation have been
applied appropriately and whether taxonomy extensions have been used in situations where relevant
elements have not been identified in the basic taxonomy defined in the ESEF Regulation;
an assessment of the correct anchoring of the applied taxonomy extensions to the core taxonomy defined
in the ESEF Regulation.
We believe that the evidence we have obtained provides a sufficient and appropriate basis for our opinion
on the label's compliance with the requirements of the ESEF Regulation.
Opinion on compliance with the requirements of the ESEF Regulation
The basis for the formulation of the auditor's opinion is the matters described above, and the opinion should
therefore be read with these matters in mind.
In our opinion, the accompanying consolidated financial statements in ESEF format have been labelled,
in all material respects, in accordance with the requirements of the ESEF Regulation
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Information on compliance with prudential regulations
The Management Board of the Parent Company is responsible for ensuring compliance of the Group's activities
with the prudential regulations resulting from the provisions of Banking Law, resolutions of the Management
Board of the National Bank of Poland and resolutions of the Financial Supervision Commission. Our task was,
on the basis of the conducted study, to provide information on whether the Group complied with its prudential
regulations. Our aim was not to express an opinion on the Group's compliance with these regulations.
Based on the work conducted during the audit we would like to inform you that we did not identify any breach
other than described in point 8.2 of the consolidated financial statements of the prudent principles and we did
not identify discrepancies that might have significant influence on the financial statement of the Bank, especially
in the area of correctness of calculation of capital ratio.
Statement Concerning Provision of Non-Audit Services
To the best of our knowledge and belief, we represent that non-audit services which we have provided to
the Parent and to its subsidiaries are not prohibited under Article 5.1 of the EU Regulation and Article 136
of the Act on Statutory Auditors. The non-audit services which we provided to the Parent and to its subsidiaries
in the audited period have been listed in point 13.5 in the Report on the Activities.
Appointment of the Auditor
We were appointed as the auditor of the Group’s consolidated financial statements by resolution 10/2021
the Parent’s Supervisory Board of the Bank of 22 February 2021. Our total uninterrupted period of engagement
to audit the Group’s consolidated financial statements is four consecutive financial years, i.e. starting from
the financial year ended 31 December 2019.
The key statutory auditor on the audit resulting in this independent auditor’s report is Dorota Snarska-Kuman.
Acting on behalf of Deloitte Audyt Spółka z ograniczoną odpowiedzialnością Sp. k. with its registered seat
in Warsaw, entered under number 73 on the list of audit firms, in the name of which the consolidated financial
statements have been audited by the key statutory auditor:
Dorota Snarska-Kuman
Registered under number 9667
Warsaw, 15 February 2023