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January 2022

INDEPENDENT REPORT FOR SUSTAINABILITY DISCLOSURES

By Himanshu V. Kishnadwala
Chartered Accountant
Reading Time 12 mins

Compiler’s Note: Sustainability reporting is fast gaining importance across all major economies. SEBI has also mandated the top listed companies to make disclosures related to Sustainability (or ESG as they are popularly called). Investors are increasingly asking for independent verification of the data included in these reports. Given below are two instances of large multinational entities who have obtained independent reports on the performance data included in the Sustainability Reports for 2020. In a recent development, the IFRS Foundation announced on 3rd November, 2021 the formation of the new International Sustainability Standards Board (ISSB). The ISSB will develop a comprehensive global baseline of high-quality sustainability disclosure standards which are focused on enterprise value.

(Readers may also refer to BCAJ August, 2021 (Page 79) for an illustrative Independent Assurance statement obtained by a large company in India.)

A.P. MOLLER – MAERSK A/S

Independent Assurance ReportTo the stakeholders of A.P. Møller – Mærsk A/S,

A.P. Møller – Mærsk A/S engaged us to provide limited assurance on the Performance data stated on page 44 in their Sustainability Report for the period 1st January – 31st December, 2020 (the Performance data).

Our conclusion

Based on the procedures we performed and the evidence we obtained, nothing came to our attention that causes us not to believe that the Performance data in the A.P. Møller – Mærsk A/S Sustainability Report are free of material misstatements and prepared, in all material respects, in accordance with the Sustainability Accounting Principles as stated on pages 46-47 (the ‘Sustainability Accounting Principles’).

This conclusion is to be read in the context of what we state in the remainder of our report.

What we are assuring

The scope of our work was limited to assurance over Performance data as stated on page 44 in the A.P. Møller – Mærsk A/S Sustainability Report, 2020. Scope 3 carbon emissions have not been in the scope for our review of the 2020 Performance data.

Professional standards applied and level of assurance

We performed a limited assurance engagement in accordance with International Standard on Assurance Engagements 3000 (Revised) ‘Assurance Engagements other than Audits and Reviews of Historical Financial Information’ and in respect of the greenhouse gas emissions, in accordance with International Standard on Assurance Engagements 3410 ‘Assurance engagements on greenhouse gas statements’. Greenhouse gas quantification is subject to inherent uncertainty because of incomplete scientific knowledge used to determine emission factors and the values needed to combine emissions of different gases. A limited assurance engagement is substantially less in scope than a reasonable assurance engagement in relation to both the risk assessment procedures, including an understanding of internal control, and the procedures performed in response to the assessed risks; 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.

Our independence and quality control

We have complied with the Code of Ethics for Professional Accountants issued by the International Ethics Standards Board for Accountants, which includes independence and other ethical requirements founded on fundamental principles of integrity, objectivity, professional competence and due care, confidentiality and professional behaviour. The firm applies International Standard on Quality Control 1 and accordingly maintains a comprehensive system of quality control, including documented policies and procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements. Our work was carried out by an independent multidisciplinary team with experience in sustainability reporting and assurance.

Understanding reporting and measurement methodologies

The Performance data need to be read and understood together with the Sustainability Accounting Principles on pages 46-47 which Management are solely responsible for selecting and applying. The absence of a significant body of established practice on which to draw to evaluate and measure non-financial information allows for different, but acceptable, measurement techniques and can affect comparability between entities and over time.

Work performed

We are required to plan and perform our work in order to consider the risk of material misstatement of the Performance data. In doing so and based on our professional judgement, we:

*    Conducted interviews with management at corporate and Brand level responsible for the sustainability strategy, management and reporting;

*    Performed an assessment of materiality and the selection of topics for the Sustainability Report and comparison with the results of a media search;

*    Read and evaluated reporting guidelines and internal control procedures at corporate level and reporting entity level regarding the Performance data to be consolidated in the 2020 Sustainability Report;

*    Conducted analytical review of the data and trend explanations submitted by all reporting entities to A.P. Moller – Maersk Accounting & Controlling for consolidation; and

*    Evaluated evidence.

Statement on other sustainability information mentioned in the report
The management of A.P. Møller – Mærsk A/S is responsible for other sustainability information communicated in the 2020 Sustainability report. The other sustainability information on pages 4-43 of the Sustainability report comprises the sections Introduction, Strategic sustainability priorities, Responding to a pandemic, Responsible business practices and Progress overview regarding A.P. Møller – Mærsk A/S’s 2020 sustainability approach, activities and results.

Our conclusion on the Performance data on page 44 does not cover other sustainability information and we do not express an assurance conclusion thereon. In connection with our review of the Performance data, we read the other sustainability information in the 2020 A.P. Møller – Mærsk A/S Sustainability Report and, in doing so, considered whether the other sustainability information is materially inconsistent with the Performance data or our knowledge obtained in the review, or otherwise appear to be materially misstated. We have nothing to report in this regard.

Management’s responsibilities

The management of A.P. Møller – Mærsk A/S is responsible for:

*    Designing, implementing and maintaining internal control over information relevant to the preparation of the Performance data and information in the Sustainability Report that are free from material misstatement, whether due to fraud or error;

*  Establishing objective Sustainability Accounting Principles for preparing Performance data; and

*  Measuring and reporting the Performance data in the Sustainability Report based on the Sustainability Accounting Principles.

Our responsibility

We are responsible for:

* Planning and performing the engagement to obtain limited assurance about whether the Performance data for the period 1st January-31st December, 2020 are free from material misstatements and are prepared, in all material respects, in accordance with the Sustainability Accounting Principles;

* Forming an independent conclusion based on the procedures performed and the evidence obtained; and

* Reporting our conclusion to the stakeholders of A.P. Møller – Mærsk A/S.

VOLKSWAGEN AG

Independent Auditors’ Limited Assurance Report

The assurance engagement performed by Ernst & Young (EY) relates exclusively to the German version of the combined non-financial report 2020 of Volkswagen AG. The following text is a translation of the original German Independent Assurance Report.

To Volkswagen AG, Wolfsburg

We have performed a limited assurance engagement on the separate non-financial report of Volkswagen AG according to § 289b HGB (‘Handelsgesetzbuch’: German Commercial Code), which is combined with the separate non-financial report of the group according to § 315b HGB, consisting of the disclosures in the Sustainability Report 2020 highlighted in colour for the reporting period from 1st January, 2020 to 31st December, 2020 (hereafter combined non-financial report). Our engagement exclusively relates to the information highlighted in colour as detailed above in the German PDF version of the Sustainability Report. Our engagement did not include any disclosures for prior years.

Management’s responsibility

The legal representatives of the Company are responsible for the preparation of the combined non-financial report in accordance with §§ 315c in conjunction with 289c to 289e HGB.

This responsibility includes the selection and application of appropriate methods to preparing the combined non-financial report as well as making assumptions and estimates related to individual disclosures which are reasonable in the circumstances. Furthermore, the legal representatives are responsible for such internal controls that they have considered necessary to enable the preparation of a combined non-financial report that is free from material misstatement, whether due to fraud or error.

Auditor’s declaration relating to independence and quality control

We are independent from the Company in accordance with the provisions under German commercial law and professional requirements and we have fulfilled our other professional responsibilities in accordance with these requirements.

Our audit firm applies the national statutory regulations and professional pronouncements for quality control, in particular the bylaws regulating the rights and duties of Wirtschaftsprüfer and vereidigte Buchprüfer in the exercise of their profession [Berufssatzung für Wirtschaftsprüfer und vereidigte Buchprüfer] as well as the IDW Standard on Quality Control 1: Requirements for Quality Control in audit firms [IDW Qualitätssicherungsstandard 1: Anforderungen an die Qualitätssicherung in der Wirtschaftsprüferpraxis (IDW QS 1)].

Auditor’s responsibility

Our responsibility is to express a limited assurance conclusion on the combined non-financial report based on the assurance engagement we have performed.

We conducted our assurance engagement in accordance with the International Standard on Assurance Engagements (ISAE) 3000 (Revised): Assurance Engagements other than Audits or Reviews of Historical Financial Information, issued by the International Auditing and Assurance Standards Board (IAASB). This Standard requires that we plan and perform the assurance engagement to obtain limited assurance about whether the combined non-financial report of the Company has been prepared, in all material respects, in accordance with §§ 315c in conjunction with 289c to 289e HGB. In a limited assurance engagement the assurance procedures are less in extent than for a reasonable assurance engagement and therefore a substantially lower level of assurance is obtained. The assurance procedures selected depend on the auditor’s professional judgment.

Within the scope of our assurance engagement, which has been conducted between September, 2020 and February, 2021, we performed amongst others the following assurance and other procedures:

  • Inquiries of relevant managerial employees of the group regarding the conducting of the materiality analysis as well as the selection of topics for the combined non-financial report, the risk assessment and the concepts of Volkswagen for the topics that have been identified as material,
  • Inquiries of relevant managerial employees responsible for data capture and consolidation as well as the preparation of the combined non-financial report, to evaluate the reporting processes, the data capture and compilation methods as well as internal controls to the extent relevant for the assurance of the combined non-financial report,
  • Identification of likely risks of material misstatement in the combined non-financial report,
  • Inspection of relevant documentation of the systems and processes for compiling, aggregating and validating data in the relevant areas in the reporting period,
  • Analytical evaluation of disclosures in the combined non-financial report at parent company and group level,
  • Inquiries and inspection of documents on a sample basis relating to the collection and reporting of selected data,
  • Evaluation of the implementation of group management requirements, processes and specifications regarding data collection through onsite visits at selected sites of the Volkswagen Group:

*    Audi AG (Ingolstadt, Germany)

*    Dr. Ing. h.c. F. Porsche AG (Stuttgart-Zuffenhausen, Germany)

*    FAW-Volkswagen Automotive Co. Ltd. (Changchun, China)

*    SAIC Volkswagen Automotive Co. Ltd. Shanghai (Anting, China)

*    Scania Latin America Ltda. (São Paulo, Brazil)

*    SEAT S.A. (Martorell, Spain)

*    ŠKODA AUTO a.s. (Mladá Boleslav, Czech Republic)

*    Volkswagen AG (Wolfsburg, Germany)

*    Volkswagen AG (Kassel, Germany)

*    Volkswagen de México, S.A. de C.V. (Puebla, Mexico)

  • Comparison of disclosures with corresponding data in the group management report, which is combined with the management report of Volkswagen AG,
  • Evaluation of the presentation of disclosures in the combined non-financial report.

Assurance conclusion

Based on our assurance procedures performed and assurance evidence obtained, nothing has come to our attention that causes us to believe that the combined non-financial report of Volkswagen AG for the period from 1st January, 2020 to 31st December, 2020 has not been prepared, in all material respects, in accordance with §§ 315c in conjunction with 289c to 289e HGB.

Intended use of the assurance report

We issue this report on the basis of the engagement agreed with Volkswagen AG. The assurance engagement has been performed for the purposes of the Company and the report is solely intended to inform the Company as to the results of the assurance engagement and must not be used for purposes other than those intended. The report is not intended to provide third parties with support in making (financial) decisions.

Engagement terms and liability

The ‘General Engagement Terms for Wirtschaftsprüfer and Wirtschaftsprüfungsgesellschaften [German Public Auditors and Public Audit Firms]’ dated 1st January, 2017 are applicable to this engagement and also govern our relations with third parties in the context of this engagement (www.de.ey.com/general-engagement-terms). In addition, please refer to the liability provisions contained therein at No. 9 and to the exclusion of liability towards third parties. We assume no responsibility, liability or other obligations towards third parties unless we have concluded a written agreement to the contrary with the respective third party or liability cannot effectively be precluded.

We make express reference to the fact that we do not update the assurance report to reflect events or circumstances arising after it was issued unless required to do so by law. It is the sole responsibility of anyone taking note of the result of our assurance engagement summarised in this assurance report to decide whether and in what way this result is useful or suitable for their purposes and to supplement, verify or update it by means of their own review procedures.

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