TRANSLATORS’ EXPLANATORY NOTE
The
English
content
of
this
report
is
a
free
translation
of
the
statutory
auditor’s
limited
assurance
report
on
the
sustainability
statement
of
the
below-mentioned
Polish
Company.
In
Poland
the
sustainability
statement
as
well
as
the
auditor’s
report
should
be
prepared
and
presented
in
Polish
language
and
in
accordance
with
Polish
legislation,
and
the
sustainability
standards
generally
adopted in Poland.
The
accompanying
translation
has
not
been
reclassified
or
adjusted
in
any
way
to
conform
to
the
accounting
principles
generally
accepted
in
countries
other
than
Poland,
but
certain
terminology
current
in
Anglo-Saxon
countries
has
been
adopted
to
the
extent
practicable.
In
the
event
of
any
discrepancies in interpreting the terminology, the Polish language version is binding.
PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt sp. k.
, ul.
Polna 11, 00-633 Warsaw, Poland, T: +48 (22) 746
4000,
PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt sp. k.
is entered into the National Court Register maintained by
the District Court for the Capital City of Warsaw, under KRS number 0000750050, NIP 526-021-02-28. The seat of the Company is in Warsaw at
Polna 11.
Independent statutory auditor's limited assurance report on the
sustainability statement
To th
e General Shareholders’ Meeting and the Supervisory Bo
ard of Santander Bank Polska S.A.
We have conducted a limited assurance engagement
on the “Consolidated Sustainability Statement of
Santander Bank Polska Group 2024” prepared by Santander Bank Polska S.A. (the “Company”) as of
31 December 2024 and for the year then ended and included in chapter XIII. of the Management
Board Report on Santander Bank Polska Group Performance in 2024 (including Report on Santander
Bank Polska S.A. Performance) (the “Sustainability statement of the capital group”).
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 capital group is not compliant, in all material respects, with
Chapter 6c of the Accounting Act of 29 September 1994 (the “Accounting Act”), as well as with the
European Sustainability Reporting Standards (the “ESRS”);
•
the materiality assessment process conducted by the Company to identify information included in
the Sustainability statement of the capital group (“Materiality Assessment Process”) is not
compliant, in all material respects, with the ESRS
;
•
the Sustainability statement of the capital group is not compliant, in all material respects, with the
reporting requirements set out in Article 8 of the 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 (the “Taxonomy Regulation”)
.
Basis for opinion
We conducted our limited assurance engagement in accordance with National Standard on Assurance
Services for Sustainability Reporting 3002PL - Limited assurance engagement on the sustainability
statement (the “NSAE 3002PL”) and, where appropriate, with National Standard on Assurance
Engagements Other than Audits and Reviews 3000 (R) in the wording of International Standard on
Assurance Engagements 3000 (Revised) - Assurance Engagements Other than Audits or Reviews of
Historical Financial Information (the “NSAE 3000 (R)”) adopted by the resolutions of the National
Board of Statutory Auditors
.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our
opinion. Our responsibility under NSAE 3002PL and, where applicable, NSAE 3000(R) is further
described in the
Responsibilities of statutory auditor providing the sustainability statement assurance
section
.
2
Our independence and quality management
We have complied with the independence requirements and other ethical requirements set out in the
“Handbook of the International Code of Ethics for Professional Accountants (including International
Independence Standards)” (“Code of ethics”) adopted by resolution of the National Board of Statutory
Auditors, which is based on the fundamental principles of integrity, objectivity, professional
competence and due care, confidentiality, and professional behaviour, as well as with the
requirements contained in the Act of 11 May 2017 on Statutory Auditors, Audit Firms, and Public
Oversight (the “Act on Statutory Auditors, Audit Firms and Public Oversight”) and in EU Regulation No.
537/2014 of 16 April 2014 on specific requirements regarding statutory audit of public interest entities.
We have fulfilled other ethical obligations in accordance with the
aforementioned regulations and the
Code of ethics
.
Our firm applies the National Quality Control Standard 1 in the wording of the International Standard
on Quality Management (PL) 1 – Quality Management for Companies that Perform Audits or Reviews
of Financial Statements, or Other Assurance or Related Services Engagements issued by the
International Auditing and Assurance Standards Board and adopted by the resolution of the Council of
the Polish Agency for Audit Oversight, as well as the provisions of the Act on Statutory Auditors, Audit
Firms and Public Oversight. This standard requires us to design, implement, and operate a system of
quality management, including policies or procedures regarding compliance with ethical requirements,
professional standards, and applicable legal and regulatory requirements.
Responsibilities for the Sustainability statement of the capital group
The management of the Company is responsible for designing and conducting the Materiality
Assessment Process in accordance with the ESRS, to identify information included in the
Sustainability statement of the capital group in accordance with the ESRS and for disclosing this
process in section 1.1. Impact, risk and opportunity management to the Sustainability statement of the
capital group. These responsibilities include, among others:
•
understanding the context in which the Group’s activities and business relationships take place
and developing an understanding of its 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 the materiality of the identified impacts, risks and opportunities related to
sustainability matters by selecting and applying appropriate thresholds; and
•
making assumptions that are reasonable in the circumstances.
Management of the Company is further responsible for preparation of the Sustainability statement of
the capital group in accordance with Chapter 6c of the Accounting Act, including, among others, the
following:
•
compliance with the ESRS
;
•
compliance of the Sustainability statement of the capital group, including the disclosures in
subsection Disclosures related to Regulation 2020/852 EU Taxonomy in Chapter 2. Environmental
information - climate change (ESRS E1) of the Sustainability statement of the capital group with
Article 8 of the Taxonomy Regulation
;
3
•
designing, implementing, and maintaining internal control that the Company's management
determines is necessary to enable the preparation of the Sustainability statement of the capital
group that is free from material misstatements, whether due to fraud or error; and
•
the selection and application of appropriate sustainability reporting methods and making
assumptions and estimates that are reasonable in the circumstances.
Members of the Supervisory Board of the Company are responsible for overseeing the reporting
process of the Sustainability statement of the capital group.
Inherent limitations in the preparation of the Sustainability statement of the capital group
As discussed in section Disclosures in relation to special circumstances (BP-2) of the Sustainability
statement of the capital group, for metrics where access to full actual data is limited, estimates are
used to ensure continuity and completeness of the information reported.
In reporting forward-looking information in accordance with the ESRS, the management of the
Company 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 Group. Actual outcomes
are likely to be different since anticipated events frequently do not occur as expected.
Responsibilities of statutory auditor providing the sustainability statement assurance
Our objectives are to plan and perform the assurance engagement to obtain limited assurance about
whether the Sustainability statement of the capital group is free from material misstatements, whether
due to fraud or error, and to issue a limited assurance report on the Sustainability statement of the
capital group containing our opinion. Misstatements can arise from fraud or error and are considered
material if, individually or in aggregate, they could reasonably be expected to influence the decisions
of users taken on the basis of the Sustainability statement of the capital group as a whole
.
As part of a limited assurance engagement in accordance with NSAE 3002PL and NSAE 3000 (R), we
exercise professional judgment and maintain professional skepticism throughout the engagement.
Our responsibilities in respect of the Sustainability statement of the capital group, in relation to the
Materiality Assessment Process, include
:
•
obtaining an understanding of the Materiality Assessment Process, but not for the purpose of
providing a conclusion on the effectiveness of the Materiality Assessment Process, including the
outcome of the Materiality Assessment Process
;
•
considering whether the information identified addresses the applicable disclosure requirements of
the ESRS; and
•
designing and performing procedures to evaluate whether the Materiality Assessment Process is
consistent with the Company’s description of its Materiality Assessment
Process set out in section
1.1. Impact, risk and opportunity management of the Sustainability statement of the capital group.
Our other responsibilities in respect of the Sustainability statement of the capital group include:
•
identifying where material misstatements are likely to arise, whether due to fraud or error; and
•
designing and performing procedures responsive to where material misstatements are likely to
arise in the Sustainability statement of the capital group. 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.
4
Summary of the work performed
A limited assurance engagement involves performing procedures to obtain evidence about the
Sustainability statement of the capital group. The procedures in a limited assurance engagement vary
in nature and timing from, and are less in extent than for, a reasonable assurance engagement.
Consequently, the level of assurance obtained in a limited assurance engagement is substantially
lower than the assurance that would have been obtained had a reasonable assurance engagement
been performed.
The nature, timing and extent of procedures selected depend on professional judgement, including the
identification of disclosures where material misstatements are likely to arise in the Sustainability
statement of the capital group, whether due to fraud or error
.
In conducting our limited assurance engagement, with respect to the Materiality Assessment Process,
we:
•
obtained an understanding of the Materiality Assessment Process by:
o
performing inquiries to understand the sources of the information used by
management (e.g., stakeholder engagement, business plans and strategy
documents);
o
reviewing the Company’s internal documentation of its Materiality Assessment
Process; and
•
evaluated whether the evidence obtained from our procedures with respect to the Materiality
Assessment Process implemented by the Company was consistent with the description of the
Materiality Assessment Process set out in section 1.1. Impact, risk and opportunity management
of the Sustainability statement of the capital group.
In conducting our limited assurance engagement, with respect to the Sustainability statement of the
capital group, we:
•
obtained an understanding of the reporting process relevant to the preparation of the Sustainability
statement of the capital group by obtaining understanding of the Group’s control environment,
processes, and information system relevant to the preparation of the Sustainability statement of
the capital group, but not for the purpose of expressing an opinion on the effectiveness of the
Group’s internal control;
•
evaluated whether the information identified by the Materiality Assessment Process is included in
the Sustainability statement of the capital group;
•
evaluated whether the structure and the presentation of the Sustainability statement of the capital
group is in accordance with the ESRS;
•
performed inquiries of the Company’s employees involved in the preparation of the Sustainability
statement of the capital group and analytical procedures on selected information in the
Sustainability statement of the capital group;
•
performed substantive assurance procedures on selected information in the Sustainability
statement of the capital group;
•
where applicable, compared disclosures in the Sustainability statement of the capital group with
the corresponding disclosures in the consolidated financial statements and the management
report of the Group;
5
•
evaluated the methods, assumptions and data for developing estimates and forward-looking
information;
•
obtained an understanding of the Company's process to identify taxonomy-eligible and taxonomy-
aligned economic activities and the corresponding disclosures in the Sustainability statement of
the capital group.
The comparative data as of 31 December 2023, and for the year then ended included in the
Sustainability statement of the capital group was not subject to sustainability assurance. Our opinion is
not modified in respect of this matter.
Acting on behalf of PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt
sp.k., a company registered on the list of audit firms under number 144:
Original report is signed in Polish language
Key Statutory Auditor providing the sustainability statement assurance
No. in the registry
13488
