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1
PricewaterhouseCoopers Polska spółka z ograniczoną
odpowiedzialnością Audyt sp.k., ul. Polna 11, 00-633 Warsaw,
Poland, T: +48 (22) 746 4000, F: +48 (22) 746 4040
PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt sp.k. with registered
office at ul.
Polna 11, 00-633 Warsaw, entered into National Court Register by the District Court for the
Capital City of Warsaw, XII Commercial Division of the National Court Register under KRS No
0000750050, Tax ID No (NIP) 5260210228.
Independent statutory auditor's limited assurance
report on the sustainability statement
To the Shareholders’ Meeting and the Supervisory Board of Arctic Paper S.A.
Opinion
We have conducted a limited assurance engagement on the sustainability reporting of capital group
prepared by Arctic Paper S.A. (the „Company”) as of 31 December 2025 and for the year then ended
and included in chapter Sustainability reporting of the Arctic Paper SA Management Board’s Report
2025 (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.
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 behavior, 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 chapter 1.
General Information 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 the 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 chapter
2. Environment-related information with Article 8 of the Taxonomy Regulation;
•
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 reporting methods of the Sustainability statement of the
capital group and making assumptions and estimates that are reasonable in the circumstances.
The Supervisory Board of the Company is responsible for overseeing the reporting process of the
Sustainability statement of the capital group.
Inherent limitations in preparing the Sustainability statement of the capital
group
Greenhouse gas emissions quantification is subject to inherent uncertainty because of incomplete
scientific knowledge used to determine emissions factors and the values needed to combine emissions
of different gases.
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 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 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 judgement and maintain professional scepticism 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 chapter 1.
General Information to 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.
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:
−
performing inquiries to understand the sources of the information used by management (e.g.,
stakeholder engagement, business plans and strategy documents);
−
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 chapter 1. General Information to 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;
•
evaluated the methods 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
.
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 12637
