Auditor`s Report
Assurance report of the independent German Public Auditor on a limited assurance engagement in relation to the combined non-financial statement included in the combined management report.
To the NORMA Group SE, Maintal
Assurance Conclusion
We have conducted a limited assurance engagement on the combined non-financial statement of NORMA Group SE for the financial year from 1. January to 31. December 2024, included in section “Combined Non-financial Statement” of the combined management report, prepared to fulfil the requirements of Sections 315b and 315c of the HGB [Handelsgesetzbuch: German Commercial Code] for a consolidated non-financial statement and Sections §§ 289b to 289e of the HGB for a non-financial statement of the company, including the information contained in this combined non-financial statement to fulfill the requirements of Article 8 of Regulation (EU) 2020/852 (hereinafter the "consolidated non-financial reporting").
Not subject to our assurance engagement are the external sources of documentation mentioned in the consolidated non-financial reporting which are marked as unassured.
Based on the procedures performed and the evidence obtained, nothing has come to our attention that causes us to believe that the accompanying consolidated non-financial reporting for the financial year from 1. January to 31. December 2024 is not prepared, in all material respects, in accordance with Sections 315b and 315c HGB for a consolidated non-financial statement, Sections §§ 289b to 289e of the HGB for a non-financial statement of the company, the requirements of Article 8 of Regulation (EU) 2020/852 and the supplementary criteria presented by the executive directors of the Company.
We do not express an assurance conclusion on the external sources of documentation mentioned in the consolidated non-financial reporting which are marked as unassured.
Basis for the Assurance Conclusion
We conducted our assurance engagement in accordance with 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).
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 is substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been performed.
Our responsibilities under ISAE 3000 (Revised) are further described in the section “German Public Auditor’s Responsibilities for the Assurance Engagement on the consolidated non-financial reporting”.
We are independent of the entity in accordance with the requirements of European law and German commercial and professional law, and we have fulfilled our other German professional responsibilities in accordance with these requirements. Our audit firm has applied the requirements for a system of quality control as set forth in the IDW Quality Management Standard issued by the Institut der Wirtschaftsprüfer [Institute of Public Auditors in Germany] (IDW): Requirements for Quality Management in the Audit Firm (IDW QMS 1 (09.2022)) and International Standard on Quality Management (ISQM) 1 issued by the IAASB. We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our assurance conclusion.
Emphasis of Matter – Principles for the preparation of the consolidated non-financial reporting
Without modifying our audit opinion, we refer to the disclosures in the consolidated non-financial reporting, which describe the principles for the preparation of the consolidated non-financial reporting. Accordingly, the Company has applied the European Sustainability Reporting Standards (ESRS) to the extent specified in Section “Consolidated Non-financial Statement – General Disclosures” of the consolidated non-financial reporting.
Responsibilities of the Executive Directors and the Supervisory Board for the consolidated non-financial reporting
The executive directors are responsible for the preparation of the consolidated non-financial reporting in accordance with the applicable German legal and other European requirements as well as with the supplementary criteria presented by the executive directors of the Company and for designing, implementing and maintaining such internal control that they have considered necessary to enable the preparation of a consolidated non-financial reporting in accordance with these requirements that is free from material misstatement, whether due to fraud (i.e., fraudulent sustainability reporting in the consolidated non-financial reporting) or error.
This responsibility of the executive directors includes establishing and maintaining the materiality assessment process, selecting and applying appropriate reporting policies for preparing the consolidated non-financial reporting, as well as making assumptions and estimates and ascertaining forward-looking information for individual sustainability-related disclosures.
The Supervisory Board is responsible for overseeing the process for the preparation of the consolidated non-financial reporting.
Inherent Limitations in Preparing the consolidated non-financial reporting
The CSRD and the applicable German legal and other European requirements contain wording and terms that are subject to considerable interpretation uncertainties and for which no authoritative, comprehensive interpretations have yet been published. As such wording and terms may be interpreted differently by regulators or courts, the legality of measurements or evaluations of sustainability matters based on these interpretations is uncertain. As further set forth in sections “Turnover KPI (Key Performance Indicator) definition”, “Capex KPI definition”, “OpEx KPI definition” regarding the EU Taxonomy, as well as section “E5-4 Resource inflows - Products and materials” of the consolidated non-financial reporting, the quantification of the non-financial performance indicators, especially regarding EU Taxonomy eligible turnover, CapEx and OpEx, as well as secondary materials is also subject to inherent uncertainties due to restricted availability of data and the necessity of estimations.
These inherent limitations also affect the assurance engagement on the consolidated non-financial reporting.
German Public Auditor’s Responsibilities for the Assurance Engagement on the consolidated non-financial reporting
Our objective is to express a limited assurance conclusion, based on the assurance engagement we have conducted, on whether any matters have come to our attention that cause us to believe that the consolidated non-financial reporting has not been prepared, in all material respects, in accordance with the applicable German legal and other European requirements and the supplementary criteria presented by the company’s executive directors, and to issue an assurance report that includes our assurance conclusion on the consolidated non-financial reporting.
As part of a limited assurance engagement in accordance with ISAE 3000 (Revised), we exercise professional judgment and maintain professional skepticism. We also:
•obtain an understanding of the process used to prepare the consolidated non-financial reporting, including the materiality assessment process carried out by the entity to identify the disclosures to be reported in the consolidated non-financial reporting.
•identify disclosures where a material misstatement due to fraud or error is likely to arise, design and perform procedures to address these disclosures and obtain limited assurance to support the assurance conclusion. The risk of not detecting a material misstatement resulting from fraud is higher than the risk of not detecting a material misstatement resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations or the override of internal control. In addition, the risk of not detecting a material misstatement in information obtained from sources not within the entity’s control (value chain information) is ordinarily higher than the risk of not detecting a material misstatement in information obtained from sources within the entity’s control, as both the entity’s executive directors t and we as practitioners are ordinarily subject to restrictions on direct access to the sources of the value chain information.
•consider the forward-looking information, including the appropriateness of the underlying assumptions. There is a substantial unavoidable risk that future events will differ materially from the forward-looking information.
Summary of the Procedures Performed by the German Public Auditor
A limited assurance engagement involves the performance of procedures to obtain evidence about the sustainability information. The nature, timing and extent of the selected procedures are subject to our professional judgment.
In performing our limited assurance engagement, we among others:
•evaluated the suitability of the criteria as a whole presented by the executive directors in the consolidated non-financial reporting
•inquired of the executive directors and relevant employees involved in the preparation of the consolidated non-financial reporting about the preparation process, including the materiality assessment process carried out by the entity to identify the disclosures to be reported in the consolidated non-financial reporting, and about the internal controls relating to this process
•evaluated the reporting policies used by the executive directors to prepare the consolidated non-financial reporting
•evaluated the reasonableness of the estimates and related information provided by the executive directors.
•performed analytical procedures and made inquiries in relation to selected information in the consolidated non-financial reporting
•conducted site visits
•considered the presentation of the information in the consolidated non-financial reporting
•considered the process for identifying taxonomy-eligible and taxonomy-aligned economic activities and the corresponding disclosures in the consolidated non-financial reporting.
Restriction of Use / Clause on General Engagement Term
This assurance report is solely addressed to NORMA Group SE.
The engagement, in the performance of which we have provided the services described above on behalf of NORMA Group SE, was carried out on the basis of the General Engagement Terms for Wirtschaftsprüferinnen, Wirtschaftsprüfer und Wirtschaftsprüfungsgesellschaften (Allgemeine Auftragsbedingungen für Wirtschaftsprüferinnen, Wirtschaftsprüfer und Wirtschaftsprüfungsgesellschaften) dated as of January 1, 2024 (www. kpmg.de/AAB_2024). By taking note of and using the information as contained in our report each recipient confirms to have taken note of the terms and conditions stipulated in the aforementioned General Engagement Terms (including the liability limitations specified in item No. 9 included therein) and acknowledges their validity in relation to us.
Mannheim, March 18th, 2025
KPMG AG
Wirtschaftsprüfungsgesellschaft
Forstreuter Beyer
German Public Auditor German Public Auditor
Legend
These contents are part of the Non-financial Group Report and were subject to a separate limited assurance examination.