Deloitte Assurance Polska
spółka z ograniczoną odpowiedzialnością sp. k.
(formerly: Deloitte Assurance sp. z o.o.)
al. Jana Pawła II 22
00-133 Warszawa
Polska
Tel.: +48 22 511 08 11
Fax: +48 22 511 08 13
www.deloitte.com/pl
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is a legally separate and independent entity. Please see www.deloitte.com/pl/about for a detailed description of the legal structure of Deloitte Touche Tohmatsu
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INDEPENDENT AUDITOR'S LIMITED ASSURANCE REPORT
ON SUSTAINABILITY STATEMENT OF THE GROUP
To the General Meeting and the Supervisory Board of Bank Millennium S.A.
We have conducted a limited assurance engagement on the Sustainability Statement of the Bank Millennium S.A.
Group (“Group”) with Bank Millennium S.A. as the parent (the “Parent”, “Bank”), prepared as at 31 December
2024 and for the period from 1 January 2024 to 31 December 2024 (the “Sustainability Statement”), which is a
separate section in chapter II Sustainability Reporting of the Management Board Report on the activity of Bank
Millennium S.A. and Capital Group of Bank Millennium S.A. in 2024.
Identification of Applicable Criteria
The criteria applicable to the Sustainability Statement of the Group are:
− the provisions of Chapter 6c of the Accounting Act of 29 September 1994 (Journal of Laws of 2023, item 120,
as amended) (the “Accounting Act”),
− the sustainability reporting standards defined in Commission Delegated Regulation (EU) 2023/2772 of 31 July
2023 supplementing Directive 2013/34/EU of the European Parliament and of the Council with regard to
sustainability reporting standards (“ESRS”), including the requirement for the process, carried out by
the Bank to identify the reported information to be consistent with its description in Sustainability Statement
of the Group,
− the reporting requirements contained in Article 8 Regulation (EU) 2020/852 of the European Parliament and
of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment,
amending Regulation (EU) 2019/2088 (“Regulation (EU) 2020/852”).
Inherent Limitations in Preparing the Sustainability Statement
The criteria, nature of the Sustainability Statement, and absence of long-standing established authoritative
guidance, standard applications and reporting practices allow for different, but acceptable, measurement
methodologies to be adopted which may result in variances between entities. The adopted measurement
methodologies may also impact the comparability of sustainability matters reported by different organizations and
from year to year within an organization as methodologies evolve.
In reporting forward looking information in accordance with ESRS, management of the Bank is required to prepare
the forward-looking information on the basis of disclosed assumptions about events that may occur in the future
and possible future actions by the Bank. Actual outcome is likely to be different since anticipated events frequently
do not occur as expected.
In determining the disclosures in the Sustainability Statement of the Group, Management of the Bank interprets
undefined legal and other terms. Undefined legal and other terms may be interpreted differently, including the
legal conformity of their interpretation and, accordingly, are subject to uncertainties.
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We draw your attention to the following specific limitations:
Sustainability Statement of the Group as applied by all companies includes information based on climate-related
scenarios that are subject to inherent uncertainty because of incomplete scientific and economic knowledge about
the likelihood, timing, or effect of possible future physical and transitional climate-related impacts. For the
avoidance of doubt, the scope of our engagement and our responsibilities will not include performing work
necessary for any assurance on the reliability, proper compilation, or accuracy of the prospective information.
Any supply chain emissions metrics listed in the Sustainability Statement of the Group may include information
provided by Bank’s suppliers, clients and third-party sources. Our procedures will not include obtaining assurance
over the information provided by Bank’s suppliers, clients or third parties.
The Sustainability Statement of the Group may include metrics that are derived from reported events relating to
employees and subcontractors or clients. As such, our testing may not identify misstatements relating to
completeness, for example in instances where events may have occurred but have not been reported.
Responsibility of the Management Board of the Bank for Sustainability Statement of the Group
Management of the Bank is responsible for designing and implementing a process to identify the information
reported in the Sustainability Statement of the Group in accordance with the ESRS (“Double Materiality
Assessment Process”) and for disclosing this process in point 15.4 Double Materiality Assessment of the
Sustainability Statement of the Group. This responsibility includes:
− understanding the context in which the Group entities’ activities and business relationships take place and
developing an understanding of their affected stakeholders;
− the identification of the actual and potential impacts (both negative and positive) related to sustainability
matters, as well as risks and opportunities that affect, or could reasonably be expected to affect, the Group’s
financial position, financial performance, cash flows, access to finance or cost of capital over the short-,
medium-, or long-term;
− the assessment of double materiality of the identified impacts, risks and opportunities related to sustainability
matters by selecting and applying appropriate thresholds; and
− making assumptions, selecting and applying appropriate methods for reporting on sustainability issues and
for determining estimates or forecasts in specific disclosures in Sustainability Statement of the Group that are
reasonable in the circumstances.
Management of the Bank is further responsible for:
− the preparation of the Sustainability Statement of the Group, in accordance with Chapter 6c of the Accounting
Act, including ESRS,
− preparing the disclosures in point 21 Disclosure of information in accordance with the EU Taxonomy (art. 8
Regulation (EU) 2020/852) of the Sustainability Statement of the Group, in compliance with Article 8 of EU
Regulation 2020/852,
− designing, implementing and maintaining such internal controls that management of the Bank determines
are necessary to enable the preparation of the Sustainability Statement of the Group that is free from material
misstatement, whether due to fraud or error,
− the selection and application of appropriate sustainability reporting methods and making assumptions and
estimates about individual sustainability disclosures that are reasonable in the circumstances.
The Management and members of Supervisory Board of the Bank are responsible for overseeing the Group’s
Sustainability Statement.
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Responsibility of the key auditor for the assurance of Sustainability Statement of the Group
We conducted the Sustainability Statement of the Group limited assurance engagement in accordance with
the National Standard on Assurance Engagements on Sustainability Reporting 3002PL – “Limited assurance
engagement on sustainability reporting” issued by the National Council of Statutory Auditors (“KSUA 3002PL”)
and, as appropriate, the National Standard on Assurance Engagements Other than an Audit and Review 3000 (Z)
in the wording of International Standard on Assurance Engagements 3000 (revised) – “Assurance Engagements
other than Audits or Reviews of Historical Financial Information” issued by the National Council of Statutory
Auditors.
The level of assurance obtained in a limited assurance engagement is lower than in a reasonable assurance
engagement because the procedures performed by the key statutory auditor in a limited assurance engagement
vary in nature and timing from those performed in a reasonable assurance engagement and are less in extent than
for a reasonable assurance engagement.
Our objectives are to plan and perform the Sustainability Statement of the Group assurance engagement to obtain
limited assurance about whether the Sustainability Statement of the Group is free from material misstatement,
whether due to fraud or error, and to issue a limited assurance report on Sustainability Statement of the Group
that includes our conclusion. Misstatements can arise from fraud or error and are considered material if,
individually or in the aggregate, they could reasonably be expected to influence decisions of users taken
on the basis of the Sustainability Statement of the Group as a whole.
As part of the Sustainability Statement of the Group limited assurance engagement in accordance with
KSUA 3002PL we exercise professional judgment and maintain professional skepticism throughout the
engagement.
Our responsibilities in respect of the Sustainability Statement of the Group, in relation to the Double Materiality
Assessment Process, include:
− obtaining an understanding of the Double Materiality Assessment Process but only to assess its compliance
with ESRS, not for the purpose of providing a conclusion on its effectiveness;
− designing and performing procedures to evaluate whether the Double Materiality Assessment Process is
consistent with the description as disclosed in point 15.4 Double Materiality Assessment to Sustainability
Statement of the Group.
Our other responsibilities in respect of the Sustainability Statement of the Group include:
− obtaining an understanding of the entity’s control environment, processes and information systems relevant
to the preparation of the Sustainability Statement of the Group but not evaluating the design of particular
control activities, obtaining evidence about their implementation or testing their operating effectiveness;
− identifying disclosures where material misstatements are likely to arise, whether due to fraud or error;
− designing and performing procedures responsive to disclosures in the Sustainability Statement of the Group
where material misstatements are likely to arise. 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.
Our Quality Management
Our firm applies the national standards on quality control adopted by resolution of the Council of the Polish Agency
for Audit Oversight. The National Standard on Quality Control 1 in the wording of the International Standard on
Quality Management (PL) 1 – “Quality Management for Firms that Perform Audits or Reviews of Financial
Statements, or Other Assurance or Related Services Engagements" requires the audit firm to design, implement
and operate a quality management system, including policies or procedures regarding compliance with ethical
requirements, professional standards and applicable legal and regulatory requirements.
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Our Independence
We have complied with the applicable independence principles and other ethical requirements specified in
the Manual of the International Code of Ethics for Professional Accountants (including International Independence
Standards) introduced by the International Ethics Standards Board for Accountants (IESBA) and adopted by the
National Council of Statutory Auditors (“the Code of Ethics”) based on the basic principles of integrity, objectivity,
professional competence and due care, confidentiality and professional behaviour, as well as other requirements
referred to in the Act of 11 May 2017 on statutory auditors, audit firms and public supervision (Journal of Laws of
2024, item 1035, as amended) and in 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 and repealing
Commission Decision 2005/909/EC. We have fulfilled our other ethical obligations in accordance with these
requirements and the Code of Ethics.
Summary of Work Performed
A limited assurance engagement involves performing procedures to obtain evidence about the Sustainability
Statement of the Group.
The nature, timing and extent of procedures selected depend on professional judgement, including the
identification of disclosures where material misstatements are likely to arise, whether due to fraud or error, in the
Sustainability Statement of the Group.
In conducting our limited assurance engagement, with respect to the Double Materiality Assessment Process, we:
− obtained an understanding of the Double Materiality Assessment Process by:
- performing inquiries to understand the sources of the information used by management,
- reviewing the Bank’s internal documentation of its Process,
- performing analytical procedures concerning selected impacts, risks and opportunities assessed during
the Group's double materiality analysis,
− evaluated whether the evidence obtained from our procedures about the Double Materiality Assessment
Process implemented by the Bank was consistent with the description of the Double Materiality Assessment
Process set out in the point 15.4 Double Materiality Assessment.
In conducting our limited assurance engagement, with respect to the Sustainability Statement of the Group, we
have performed, among the others the following procedures:
− obtained an understanding of the Bank’s reporting processes relevant to the preparation of its Sustainability
Statement of the Group by performing inquiries to understand the Bank’s control environment, processes
and information systems relevant to the preparation of the Sustainability Statement of the Group, but we
did not assess the design of specific control activities, we did not obtain evidence of their implementation
or test their effectiveness;
− evaluated whether material information identified as part of the Double Materiality Assessment Process
in order to identify the information presented in the Group's Sustainability Reporting is included therein;
− evaluated whether the structure and the presentation of the Sustainability Statement of the Group is in
accordance with the ESRS;
− performed inquires of relevant personnel and analytical procedures on selected disclosures
in the Sustainability Statement of the Group;
− performed substantive assurance procedures based on a sample basis on selected disclosures in the
Sustainability Statement of the Group;
− obtained evidence on the methods for developing material estimates and forward-looking information and
on how these methods were applied by the Group;
− obtained an understanding of the process of classifying economic activities and the relevant disclosures in
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the Sustainability Reporting of the Group in terms of their compliance with the EU Taxonomy;
− evaluated whether the processes in place ensure that the denominator and numerator of the GAR and
the GAR for assets under management are determined in a manner consistent with the applicable
definitions.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our limited
assurance report.
Limited Assurance Conclusion
Based on the procedures we have performed and the evidence we have obtained, nothing has come to our
attention that causes us to believe that:
− the Sustainability Statement of the Group is not prepared, in all material respects, in accordance with
Chapter 6c of the Accounting Act, including ESRS,
− the Materiality Assessment Process carried out by the Parent to identify the information reported in the
Sustainability Statement of the Group is not in compliance, in all material respects, with the ESRS,
− The Sustainability Statement of the Group is not in compliance, in all material respects, with the reporting
requirements in Article 8 of Regulation (EU) 2020/852.
Other Matters
Our assurance engagement does not extend to information presented in the Sustainability Statement of the Group
in respect of earlier periods than the fiscal year ending 31 December 2024.
The key statutory auditor of the Sustainability Statement of the Group assurance responsible for the assurance,
resulting in this independent auditor’s report is Barbara Gryszko.
Acting on behalf of Deloitte Assurance Polska spółka z ograniczoną odpowiedzialnością sp. k. (formerly: Deloitte
Assurance sp. z o.o.) with its registered seat in Warsaw, entered under number 4260 on the list of audit firms:
Barbara Gryszko
Registered under number 13312
Warsaw, February 24, 2025
This document is a foreign language version of the original Independent Auditor’s Report issued in Polish version
and only the original version is binding. In case of any discrepancies between the Polish and English version, the
Polish version shall prevail.