Translation – German version prevails
To PUMA SE, Herzogenaurach
We have performed a limited assurance engagement on the Separate Non-Financial Group Report of PUMA SE (hereinafter: “the Company”) in accordance with Section 315b German Commercial Code (HGB), which was combined with the Non-Financial Report of the parent company, PUMA SE, Herzogenaurach, in accordance with Section 289b German Commercial Code (HGB) for the period from January 1 to December 31, 2021 (hereinafter: “Combined Non-Financial Report”). This Combined Non-Financial Report consists of the chapter “Sustainability”, the section “Culture” in the chapter “Our People” and the sections “Compliance Management System” and “Corporate Social Responsibility” in the chapter “Corporate Governance Statement in accordance with Section 289f and Section 315d HGB” of the Annual Report 2020 of PUMA SE, Herzogenaurach.
The external documentation sources, interviews or expert opinions mentioned in the non-financial reporting are not the subject of our audit.
The executive directors of the Company are responsible for the preparation of the non-financial report in accordance with §§ 315c in conjunction with 289c to 289e German Commercial Code (HGB) 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 (hereafter referred to as “EU Taxonomy Regulation”) and the delegated acts adopted thereon, as well as with their own interpretation of the wording and terminology contained in the EU Taxonomy Regulation and the delegated acts adopted thereon, as is presented in section “EU-Taxonomy” of the consolidated non-financial report.
The responsibility of the Company’s legal representatives includes the selection and application of appropriate methods for preparing the Combined Non-Financial Report as well as making assumptions and estimates related to individual non-financial disclosures, which are reasonable in the circumstances. In addition, the legal representatives are responsible for such internal control they have determined necessary to enable the preparation of the Combined Non-Financial Report that is free from material misstatements, whether intentional or unintentional.
Some of the wording and terminology contained in the EU Taxonomy Regulation and the delegated acts adopted thereon are still subject to considerable interpretation uncertainty and have not yet been officially clarified. Therefore, the executive directors have laid down their own interpretation of the EU Taxonomy Regulation and of the delegated acts adopted thereon in section “EU-Taxonomy” of the consolidated non-financial report. They are responsible for the selection and reasonableness of this interpretation. As there is the inherent risk that indefinite legal concepts may allow for various interpretations, evaluating the legal conformity is prone to uncertainty.
The accuracy and completeness of environmental data in the non-financial report is thus subject to inherent restrictions resulting from the way how the data was collected and calculated and from assumptions made.
We have complied with the German professional requirements on independence and other professional rules of conduct.
Our firm applies the national statutory rules and professional announcements – particularly of the “Professional Charter for German Public Auditors and German Sworn Auditors” and of the IDW Quality Assurance Standard “Quality Assurance Requirements in Audit Practices” (IDW QS 1) promulgated by the Institut der Wirtschaftsprüfer (IDW) and does therefore maintain a comprehensive quality assurance system comprising documented regulations and measures in respect of compliance with professional rules of conduct, professional standards, as well as relevant statutory and other legal requirements.
Our responsibility is to express a conclusion on the non-financial report based on our work performed within our limited assurance engagement.
We conducted our work in accordance with the International Standard on Assurance Engagements 3000 (Revised) “Assurance Engagements Other than Audits or Reviews of Historical Financial Information” (ISAE 3000 (Revised)), adopted by the IAASB. This Standard requires that we plan and perform the assurance engagement so that we can conclude with limited assurance whether matters have come to our attention to cause us to believe that the non-financial report of the Company has not been prepared, in all material respects, in accordance with §§ 315c in conjunction with 289c to 289e HGB and the EU Taxonomy Regulation and the delegated acts adopted thereon, as well as with the interpretation by the executive directors presented in section “EU-Taxonomy” of the consolidated non-financial report.
The procedures performed in a limited assurance engagement 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 choice of assurance work is subject to the practitioner’s professional judgment.
Within the scope of our limited assurance engagement, which was performed from January to April 2022, we conducted, amongst others, the following audit procedures and other activities:
As the EU Taxonomy Regulation and the delegated acts adopted thereon contain indefinite legal concepts, it is necessary that the executive directors make an interpretation. The executive directors’ assessment of their interpretation’s legal conformity is prone to uncertainty, which, in this respect, is also true for our assurance engagement.
Based on the work performed and the evidence obtained, nothing has come to our attention that causes us to believe that the non-financial report of the company for the period from January 1, to December 31, 2021 has not been prepared, in material respects, in accordance with Sections. 315c in conjunction with 289c to 289e HGB and the EU Taxonomy Regulation and the delegated acts adopted thereon, as well as with the interpretation by the executive directors presented in section “EU-Taxonomy” of the consolidated non-financial report.
We do not provide an audit opinion on the external sources of documentation, interviews or expert opinions mentioned in the non-financial reporting.
We would like to point out that the assurance engagement was carried out for the purposes of the company and the report is only intended to inform the company about the findings of the assurance engagement. Consequently, it may not be suitable for any purpose other than the above. The note is therefore not intended for third parties to make (financial) decisions based on it.
Our responsibility is solely towards the company and is also limited according to the "General Terms and Conditions for Auditors and Auditing Firms" of January 1, 2017 of the Institut der Wirtschaftsprüfer in Deutschland e.V. However, we do not accept or assume liability to third parties. Our conclusion of the assurance engagement is not modified in this respect.
Munich/Germany, April 26, 2022
(Dr. Thomas Reitmayr)
German Public Auditor