ZE_PAK_SA_2024_atestacja_ESG

Grant Thornton Polska P.S.A.

ul. Abpa Antoniego Baraniaka 88 E

61-131 Poznań

Polska

T +48 61 62 51 100

F +48 61 62 51 101

www.GrantThornton.pl

Audit – Tax – Accounting – Advisory

Member of Grant Thornton International Ltd

Grant Thornton Polska Prosta spółka akcyjna. Audit Firm No. 4055.

Management Board: Tomasz Wróblewski – President of the Board, Dariusz Bednarski – Vice-President of the Board, Jan Letkiewicz – Vice-President of the Board.

Registered office address: ul. Abpa Antoniego Baraniaka 88 E, 61-131 Poznań, Poland. Tax identification number NIP: 782-25-45-999. REGON: 302021882. Bank account: 31 1090

1476 0000 0001 3554 7340. District Court Poznań – Nowe Miasto i Wilda in Poznań, 8th Commercial Division of the National Court Register, KRS No. 0001002477.

Independent Auditor’s

Limited Assurance

Report on the

Sustainability Reporting

For the General Shareholders’ Meeting and the Supervisory Board of ZE PAK Spółka Akcyjna

Opinion

We have performed a limited assurance engagement on the sustainability reporting of the Group (the Group),

in which the parent entity is ZE PAK Spółka Akcyjna (the Parent) prepared as at December 31, 2024 and for the

period from January 1, 2024 to December 31, 2024, included in a separate section of the report on the Group’s

operations included in chapter Sprawozdawczość w zakresie zrównoważonego rozwoju za 2024 rok dla grupy

kapitałowej (Sustainability Reporting).

Based on the assurance procedures we have performed and evidence we have obtained nothing has come

to our attention that causes us to believe that:

• the accompanying Sustainability Reporting is not compliant, in all material respects, with the

requirements of Chapter 6c of the Accounting Act of September 29, 1994 (the Accounting Act),

including the European Sustainability Reporting Standards (ESRS),

− the materiality assessment process conducted by the Group to identify information included in the

Sustainability Reporting (the Materiality Assessment Process) is not compliant, in all material respects,

with the ESRS,

• the accompanying Sustainability Reporting is not compliant, in all material respects, with the reporting

requirements set out in Article 8 of Regulation (EU) 2020/852 of the European Parliament and of the

Council of June 18, 2020 on the establishment of a framework to facilitate sustainable investment,

amending Regulation (EU) 2019/2088.

Basis for opinion

We conducted our engagement in accordance with the National Standard on Assurance Engagements for

Sustainability Reporting 3002PL Limited Assurance Engagement on the Sustainability Reporting adopted

by resolution of the National Council of Statutory Auditors (NSAE 3002PL) and, where appropriate, with the

National Standard on Assurance Engagements Other than Audits or Reviews 3000 (R) in the wording of

International Standard on Assurance Engagements 3000 (R) Assurance Engagements Other than Audits

or Reviews of Historical Financial Information, adopted by resolution of the National Council of Statutory

Auditors (NSAE 3000 (R)).

The level of assurance obtained in a limited assurance engagement is substantially lower than in a reasonable

assurance engagement because the procedures performed by the auditor for the sustainability reporting

assurance engagement in a limited assurance engagement vary in nature and timing from, and are less

in extent than for, a reasonable assurance engagement.

Our responsibility under those standards is further described in the Auditor’s responsibility for sustainability

reporting assurance section of our report. We are independent of the entities comprising the Group

in accordance with the International Ethics Standards Board for Accountants’ Handbook of the International

Code of Ethics for Professional Accountants (including International Independence Standards) (IESBA Code)

adopted by the National Council of Statutory Auditors’ resolution as the principles of professional ethics for

statutory auditors that apply to assurance engagements and with the independence requirements specified

in the Act

of May 11, 2017 on Statutory Auditors, Audit Firms and Public Oversight (the Act on Statutory Auditors) and

in Regulation (EU) No. 537/2014 of the European Parliament and of the Council of April 16, 2014 on specific

requirements regarding statutory audit of public-interest entities and repealing Commission Decision

2005/909/EC (the Regulation 537/2014). Moreover, we have fulfilled our other ethical obligations in accordance

with these requirements and the IESBA Code.

The audit firm applies the Act on Statutory Auditors and 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

adopted by resolution of the Council of the Polish Agency for Audit Oversight, which requires the audit firm

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.

We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our limited

assurance opinion.

Responsibilities of Management Board and Supervisory Board of the Parent for the Sustainability

Reporting

The Management Board of the Parent is responsible for:

• preparing the Sustainability Reporting in accordance with Chapter 6c of the Accounting Act, including

the ESRS,

• conducting the Materiality Assessment Process in accordance with the ESRS,

• preparing the Sustainability Reporting in accordance with Article 8 of Regulation (EU) 2020/852 of the

European Parliament and of the Council of June 18, 2020 on the establishment of a framework to

facilitate sustainable investment, and amending Regulation (EU) 2019/2088,

• designing, implementing and maintaining such internal control as the Management Board determines

is necessary to enable the preparation of Sustainability Reporting in accordance with Chapter 6c of the

Accounting Act, including the ESRS and Article 8 of Regulation (EU) 2020/852 of the European

Parliament and of the Council of June 18, 2020 on the establishment of a framework to facilitate

sustainable investment, and amending Regulation (EU) 2019/2088, that is free from material

misstatement, whether due to fraud or error,

including the Management Board of the Parent being responsible for designing and implementing the

Materiality Assessment Process and for presenting this process in the Sustainability Reporting. This

responsibility includes, among others:

• understanding the context in which the Group’s business activities and relationships take place, as

well as understanding of its affected stakeholders,

• identifying actual and potential impacts (both negative and positive) related to sustainability matters, as

well as risks and opportunities that affect, or can reasonably be expected to affect, the entity’s financial

position, financial performance, cash flows, access to finance or cost of capital in the short, medium

or long term,

• assessing the materiality of identified impacts, risks and opportunities related to sustainability matters

by selecting and applying appropriate thresholds and

• making assumptions that are reasonable in the circumstances.

The Management Board of the Parent is also responsible for selecting and applying appropriate methods for

reporting sustainability matters and determining estimates or preparing forward-looking information in individual

disclosures in the Sustainability Reporting that are reasonable in the circumstances. The members of the

Supervisory Board of the Parent are responsible for overseeing the Group’s Sustainability Reporting process.

Inherent limitations in the preparation of the Sustainability Reporting and measurement and

evaluation of related issues

There are inherent limitations regarding the measurement or evaluation of the Sustainability Reporting subject

to limited assurance engagement, which are presented below.

• When reporting forward-looking information in accordance with the ESRS, the Management Board of

the Parent is required to prepare forward-looking information based on disclosed assumptions about

events that may occur in the future and on possible future actions of the Group. The actual outcome

may be different because anticipated events often do not occur as expected.

• In determining the disclosures in the Sustainability Reporting, the Management Board of the Parent

interprets undefined legal terms and other concepts that may be interpreted in different ways, including

compliance of their interpretation with the law, and are therefore subject to uncertainty.

Auditor’s responsibility for the assurance of the Sustainability Reporting

Our objectives are to plan and perform the assurance engagement on sustainability reporting in such a manner

as to obtain limited assurance that the Sustainability Reporting is free from material misstatement, whether due

to fraud or error, and to issue a limited assurance report on sustainability reporting containing 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 decisions of users taken on the basis of this Sustainability

Reporting.

As part of a limited assurance engagement on sustainability reporting conducted in accordance with NSAE

3002PL, we exercise professional judgment and maintain professional skepticism throughout the engagement.

Our responsibility in respect to the Sustainability Reporting in relation to the Materiality Assessment Process

includes:

• obtaining an understanding of the Materiality Assessment Process solely for the purpose of assessing

its compliance with the ESRS, and not for the purpose of expressing an opinion on the effectiveness

of this process, including its outcome,

• designing and performing procedures to evaluate whether the Materiality Assessment Process is

consistent with the description of the Materiality Assessment Process presented in the Sustainability

Reporting.

Our other responsibilities with respect to the Sustainability Reporting include:

• obtaining an understanding of the entity’s control environment, processes and information systems

relevant to the preparation of the Sustainability Reporting, but not evaluating the design of specific

controls, nor obtaining evidence about their implementation or testing the operating effectiveness

of those controls,

• identifying disclosures in which material misstatements are likely to arise, whether due to fraud

or error,

• designing and performing procedures on disclosures in the Sustainability Reporting in which 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 opinion on the Sustainability Reporting does not cover other information accompanying the Sustainability

Reporting and our assurance report, or containing them, nor information contained in the Sustainability

Reporting that is not subject to assurance.

Summary of the work performed

A limited assurance engagement on sustainability reporting involves performing procedures to obtain evidence

about the Sustainability Reporting. The nature, timing and extent of procedures selected depend on

professional judgment, including the identification of disclosures in the Sustainability Reporting in which material

misstatements are likely to arise, whether due to fraud or error.

In conducting our limited assurance engagement on the Sustainability Reporting, we performed the following

procedures:

• we obtained an understanding of the Materiality Assessment Process by:

o performing inquiries to understand the sources of the information used by the Management

Board, such as stakeholder engagement, business plans and strategy documents,

o familiarising ourselves with the documentation provided to us in this regard,

• we checked whether the results of the Materiality Assessment Process were properly included in the

Sustainability Reporting,

• we obtained an understanding of the reporting process relevant to the preparation of the Sustainability

Reporting by understanding of the Group’s control environment, processes, and information system

relevant to the preparation of the Sustainability Reporting, but not for the purpose of expressing

an opinion on the effectiveness of the internal control,

• we evaluated whether the information identified by the Materiality Assessment Process is included

in the Sustainability Reporting,

• we evaluated whether the structure and the presentation of the Sustainability Reporting is in

accordance with the ESRS;

• we performed inquiries of the Parent’s employees responsible for the preparation of the Sustainability

Reporting and we performed analytical procedures on selected information in the Sustainability

Reporting,

• we performed substantive assurance procedures on selected information in the Sustainability

Reporting,

• where applicable, we compared disclosures in the Sustainability Reporting with the corresponding

disclosures other elements of the Group’s annual report (including the separate financial statements

and consolidated financial statements),

• we evaluated the methods, assumptions and data used for developing estimates and forward-looking

information,

• we analysed compliance with minimum safeguards by analysing evidence regarding methods and

assumptions used to assess compliance with minimum safeguards,

• we obtained an understanding of the Parent’s process to identify taxonomy-eligible and taxonomy-

aligned economic activities and the corresponding disclosures in the Sustainability Reporting.

Other matters – comparative information

Our assurance engagement on the Sustainability Reporting does not extend to comparative information for prior

periods. Our opinion is not modified in respect of this matter.

Paweł Zaczyński

Statutory Auditor No. 13290

Key Audit Partner for the sustainability reporting assurance engagement performing the assurance on behalf

Grant Thornton Polska Prosta spółka akcyjna,

Poznań, ul. Abpa Antoniego Baraniaka 88 E, Audit Firm No. 4055

Warsaw, April 30t

, 2025.

THIS IS TRANSLATION ONLY. The Polish language version of the report is the only valid and legally binding

version. This translation into English is provided to facilitate understanding of the report.