Independent Statutory Auditor’s Report
on the Assurance of Sustainability Reporting of
ING Bank Śląski S.A. Capital Group for 2024
Providing Limited Assurance
Forvis Mazars Audyt Sp. z o.o.
ul. Piękna 18
00-549 Warszawa
Forvis Mazars Audyt Sp. z o.o.
Sąd Rejonowy dla m. st. Warszawy, XII Wydział Gospodarczy KRS nr 0000086577, kapitał zakładowy: 1 268 000,00 PLN,
NIP: 5260215409, REGON: 011110970 2
INDEPENDENT STATUTORY AUDITOR’S REPORT ON THE ASSURANCE OF
SUSTAINABILITY REPORTING PROVIDING LIMITED ASSURANCE
Translation of the document originally issued in Polish
To the General Meeting and the Supervisory Board of ING Bank Śląski S.A.
Opinion
We carried out sustainability reporting assurance engagement providing limited assurance on the
sustainability reporting of the ING Bank Śląski S.A. Group. (the "Group"), of which ING Bank Slaski S.A.
is the parent undertaking (the "Bank") prepared as of 31 December 2024 and for the period from
1 January 2024 to 31 December 2024, included in a separate section of the Management Report of ING
Bank Śląski S.A. Group in 2024 entitled "Sustainability Statement" (the "Sustainability Reporting").
Based on the assurance procedures we performed and the evidence we obtained, nothing has come to
our attention that would lead us to believe that:
• the attached Sustainability Reporting does not comply, in all material respects, with the
requirements of Chapter 6c of the Accounting Act of 29 September 1994 (Journal of Laws 2023,
item 120, as amended) (the "Accounting Act"), including the European Sustainability Reporting
Standards ("ESRS"),
• the materiality assessment process carried out by the Bank to identify information included in the
Sustainability Reporting (the "Materiality Assessment Process") does not comply, in all material
respects, with the ESRS,
• the attached Sustainability Reporting does not comply, in all material respects, with the reporting
requirements of Article 8 of 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
and amending Regulation (EU) 2019/2088 (Official Journal of the EU L 198, 22.06.2020, p. 13,
as amended).
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Basis for Opinion
We conducted our sustainability reporting assurance engagement providing limited assurance in
accordance with the National Standard on Sustainability Assurance Services 3002PL - “Assurance
Engagement Providing Limited Assurance on Sustainability Reporting” established by the National
Council of Statutory Auditors by resolution no. 854/20a/2025 of 23 January 2025 (“KSUA 3002PL”) and
accordingly by National Standard on Assurance Engagements Other than Audit and Review 3000
(Revised) as per International Standard on Assurance Engagements 3000 (Revised) – “Assurance
Engagements Other than Audits or Reviews of Historical Financial Information” established by the
National Council of Statutory Auditors by resolution no. 3436/52e/2019 of of 8 April 2019 (“KSUA 3000
(R)”).
The level of assurance obtained under a limited assurance engagement is significantly lower than under
a reasonable assurance engagement because the procedures performed by the sustainability reporting
assurance auditor under a limited assurance engagement differ in nature and timing and are narrower in
scope than under a reasonable assurance engagement.
Our responsibilities under these standards are further described in the "Responsibilities of the statutory
auditor of sustainability reporting assurance” section.
We are independent of the Group Companies in accordance with the principles of ethics set out in the
Handbook of the International Code of Ethics for Professional Accountants (including International
Independence Standards) adopted by resolution of the National Council of Statutory Auditors No.
207/7a/2023 of 17 December 2023 on the establishment of principles of professional ethics for statutory
auditors, as amended (“Code of Ethics”), relating to assurance engagements and requirements set forth
in the Act on Statutory Auditors, Audit Firms and Public Supervision of 11 May 2017 (consolidated text,
Journal of Laws of 2024, item 1035, as amended) and Regulation (EU) No 537/2014 of 16 April 2014 on
specific requirements regarding statutory audit of public-interest entities and repealing Commission
Decision 2005/909/EC (Official Journal of the EU L 158, 27.05.2014, p. 77, as amended) which are
relevant to the sustainability reporting assurance engagement and we have fulfilled our other ethical
responsibilities in accordance with these requirements and the Code of Ethics.
Our audit firm applies National Standard on Quality Control 1 as per 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” introduced by the resolution of the Council of the
Polish Agency for Audit Oversight No 38/I/2022 of 15 November 2022, which requires the audit firm to
design, implement and operate a system of quality management, including policies or procedures
relating to compliance with ethical requirements, professional standards and applicable legal and
regulatory requirements.
We believe that the evidence that we have obtained is sufficient and appropriate to provide a basis for
our opinion of the assurance engagement performed providing limited assurance.
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Responsibility for Sustainability Reporting
The Bank's Management Board is responsible for:
• preparation of Sustainability Reporting in accordance with Chapter 6c of the Accounting Act,
including ESRS,
• conducting a Materiality Assessment Process in accordance with the ESRS,
• preparation of Sustainability Reporting in accordance with Article 8 of 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, and amending Regulation (EU) 2019/2088
(Official Journal of the EU L 198, 22.06.2020, p. 13, as amended),
• designing, implementing and maintaining such internal control as the Management Board deems
necessary for the preparation of Sustainability Reporting in accordance with Chapter 6c of the
Accounting Act, including ESRS and Article 8 of 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, and amending Regulation (EU) 2019/2088 (Official Journal of the EU L
198, 22.06.2020, p. 13, as amended), which does not contain material misstatements, whether
caused by fraud or error,
including the Bank's Management Board is responsible for developing and implementing the Materiality
Assessment Process and for presenting the process in Sustainability Reporting. These responsibilities
include, but are not limited to:
• understanding the context in which the Group's business activities and relationships are
conducted, as well as understanding the stakeholders affected by the Group,
• identification of actual and potential impacts (both negative and positive) related to sustainability
issues, as well as risks and opportunities that affect or can reasonably be expected to affect the
Group's financial position, financial performance, cash flows, access to financing or cost of capital
in the short, medium or long term,
• assessing the materiality of identified impacts, risks and opportunities related to sustainability
issues by selecting and applying appropriate thresholds, and
• making assumptions that are reasonable under the circumstances.
The Bank's Management Board is also responsible for selecting and applying appropriate methods for
reporting sustainability issues and determining estimates or preparing future-oriented information in
individual disclosures in Sustainability Reporting that are reasonable under the circumstances.
The Supervisory Board is responsible for overseeing the Group's Sustainability Reporting process.
Inherent limitations in Preparing Sustainability Reporting and Measuring and Evaluating
Sustainability Issues
There are inherent limitations to measuring or evaluating Sustainability Reporting subject to assurance
providing limited assurance, which are outlined below:
• When reporting forward-looking information in accordance with the ESRS, the Bank's
Management Board is required to prepare future-oriented information based on disclosed
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assumptions about events that may occur in the future and possible future activities of the Group.
The actual outcome may be different, as anticipated events often do not occur as expected.
• In determining disclosures in Sustainability Reporting, the Bank's Management Board interprets
undefined legal terms and other concepts. Undefined legal terms and other concepts can be
interpreted in different ways, including the legality of their interpretation, and are therefore subject
to uncertainty.
Responsibilities of the Statutory Auditor of Sustainability Reporting Assurance
Our objectives are to plan and perform the sustainability reporting assurance engagement so as to
obtain limited assurance that the Sustainability Reporting does not contain material misstatements
regardless of whether they are caused by fraud or error and to issue a sustainability reporting assurance
report providing limited assurance that includes our opinion. 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 this Sustainability Reporting.
As part of the sustainability reporting assurance engagement providing limited assurance, conducted in
accordance with KSUA 3002PL, we use professional judgment and maintain professional skepticism
throughout the engagement.
Our responsibilities with respect to Sustainability Reporting in connection with the Materiality
Assessment Process include:
• to obtain an understanding of the Materiality Assessment Process solely for the purpose of
assessing its compliance with the ESRS, and not to express an opinion on the effectiveness of
the process, including its outcome,
• to design and perform procedures to assess whether the Materiality Assessment Process is
consistent with the description of the Materiality Assessment Process outlined in Sustainability
Reporting.
Our other responsibilities with respect to Sustainability Reporting include:
• gaining an understanding of the control environment, processes and information systems
relevant to the preparation of Sustainability Reporting, but do not include evaluating the design of
individual controls, or obtaining evidence of their implementation or testing their effectiveness,
• identifying disclosures in which material misstatements may occur, regardless of whether they
are caused by fraud or error,
• designing and performing procedures for disclosures in Sustainability Reporting where material
misstatements may occur. 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;
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Summary of the Work Performed
The sustainability reporting assurance engagement providing limited assurance involves performing
procedures to obtain evidence on Sustainability Reporting. The type, timing and extent of procedures
selected depend on professional judgment, including the identification of disclosures in Sustainability
Reporting where material misstatements may occur, whether caused by fraud or error.
When conducting our sustainability reporting assurance engagement providing limited assurance:
• we gained an understanding of the Materiality Assessment Process through:
o directing inquiries to understand the sources of information used by the Bank's
management (e.g., stakeholder engagement, business plans and strategic documents),
o review the Group's internal documentation regarding its Materiality Assessment Process,
• we assessed whether the evidence obtained from our procedures for the Materiality Assessment
Process was consistent with its description as presented in the "Process for assessing material
sustainability impacts, opportunities and risks" section of Sustainability Reporting.
In performing our assurance engagement providing limited assurance on Sustainability Reporting, we
performed the following procedures:
• we gained an understanding of the Group’s reporting processes relevant to the preparation of its
Sustainability Reporting by understanding the Group’s internal control system, its processes and
IT systems, but without evaluating the design of individual controls, or obtaining evidence of their
implementation or testing their effectiveness,
• we assessed whether the material information identified through the Materiality Assessment
Process was included in Sustainability Reporting,
• we assessed whether the structure and presentation of the Sustainability Reporting complies with
the ESRS,
• we directed inquiries to relevant personnel and performed analytical procedures on selected
disclosures in Sustainability Reporting,
• we performed substantive assurance procedures based on a sample of selected disclosures in
Sustainability Reporting,
• we obtained evidence regarding the methods, assumptions and data used to develop significant
estimates and future-oriented information, and how these methods were applied,
• we gained an understanding of the process of identifying taxonomy-eligible and taxonomy-
compliant business activities and the corresponding disclosures in Sustainability Reporting,
• we gained an understanding of the process of collecting, preparing and aggregating data used in
the process of preparing Sustainability Reporting,
• we assessed whether taxonomy disclosures for key performance indicators were presented using
the standard templates required by the Taxonomy Regulation,
• we assessed whether the taxonomy disclosures reconcile, where appropriate, to the
corresponding amounts in the Group's consolidated financial statements, including the notes.
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Other Matters
Our sustainability reporting assurance engagement did not include comparative information for previous
years or periods.
Acting on behalf of Forvis Mazars Audyt Sp. z o.o. with its registered office in Warsaw, ul. Piękna 18,
entered on the list of audit firms under no. 186, on behalf of which the key statutory auditor performed
the sustainability reporting assurance engagement.
Warsaw, 7 March 2025
Małgorzata Pek
Key Auditor of Sustainability Reporting Assurance
No. 13070
