Limited Assurance Report of the Independent Auditor regarding the Combined Non-Financial Statement¹

To the Supervisory Board of METRO AG, Düsseldorf

We have performed an independent limited assurance engagement on the Combined Non-Financial Statement of METRO AG, Düsseldorf (further the “Company”), and the METRO Group as well as the section of the combined management report that are qualified as part of it through cross reference, “Business model”, for the year from 1 October 2020 to 30 September 2021 (further the “Statement”). The Statement was prepared according to §§ 315b, 315c in conjunction with §§ 289b to 289e German Commercial Code (HGB).

As disclosed in the section ‘global labour and social standards in the supply chain’, certifications on manufacturing facilities of suppliers were conducted by external certification firms mandated by METRO AG to ensure compliance with the environmental, social and health standards of the amfori Business Social Compliance Initiative (BSCI) or equivalent standards. The appropriateness and accuracy of the conclusions from the audit/certification work performed was not part of our assurance procedures.

Management’s Responsibility

The legal representatives of the Company are responsible for the preparation of the Statement in accordance with §§ 315b, 315c in conjunction with §§ 289b to 289e HGB.

This responsibility of the legal representatives includes the selection and application of appropriate methods to prepare the Statement and the use of assumptions and estimates for individual disclosures which are reasonable under the given circumstances. Furthermore, the legal representatives are responsible for the internal controls they deem necessary for the preparation of the Statement that is free of – intended or unintended – material misstatements.

Practitioner’s Responsibility

It is our responsibility to express a conclusion on the Statement based on our work performed within a limited assurance engagement.

We conducted our work in the form of a limited 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”, published by IAASB.

Accordingly, we have to plan and perform the assurance engagement in such a way that we obtain limited assurance as to whether any matters have come to our attention that cause us to believe that the Statement of the Company for the period from 1 October 2020 to 30 September 2021 has not been prepared, in all material respects, in accordance with §§ 315b and 315c in conjunction with §§ 289b to 289e HGB. We do not, however, issue a separate conclusion for each disclosure. As the assurance procedures performed in a limited assurance engagement are less comprehensive than in a reasonable assurance engagement, the level of assurance obtained is substantially lower. The choice of assurance procedures is subject to the auditor’s own judgement.

Within the scope of our engagement we performed, amongst others, the following procedures:

• Inquiries of group-level personnel who are responsible for the materiality analysis in order to understand the processes for determining material topics and respective reporting boundaries for METRO AG
• A risk analysis, including a media research, to identify relevant information on METRO AG ’s sustainability performance in the reporting period
• Evaluation of the design and the implementation of systems and processes for the collection, processing and monitoring of disclosures, including data consolidation, on environmental, employee and social matters, respect for human rights, and combatting corruption and bribery matters
• Inquiries of group-level personnel who are responsible for determining disclosures on concepts, due diligence processes, results and risks, performing internal control functions and consolidating disclosures
• Inspection of selected internal and external documents
• Analytical procedures for the evaluation of data and of the trends of quantitative disclosures as reported at group level by all sites
• Assessment of local data collection and reporting processes and reliability of reported data via a sampling survey at METRO Deutschland GmbH and MCC Ukraine via videoconference
• Assessment of the overall presentation of the disclosures

In our opinion, we obtained sufficient and appropriate evidence for reaching a conclusion for the assurance engagement.

Independence and Quality Assurance on the Part of the Auditing Firm

In performing this engagement, we applied the legal provisions and professional pronouncements regarding independence and quality assurance, in particular the Professional Code for German Public Auditors and Chartered Accountants (in Germany) and the quality assurance standard of the German Institute of Public Auditors (Institut der Wirtschaftsprüfer, IDW) regarding quality assurance requirements in audit practice (IDW QS 1).

Conclusion

Based on the procedures performed and the evidence obtained, nothing has come to our attention that causes us to believe that the Statement of METRO AG for the period from 1 October 2020 to 30 September 2021 has not been prepared, in all material respects, in accordance with §§ 315b and 315c in conjunction with §§ 289b to 289e HGB.

Restriction of Use/Clause on General Engagement Terms

This report is issued for purposes of the Supervisory Board of METRO AG, Düsseldorf, only. We assume no responsibility with regard to any third parties.

Our assignment for the Supervisory Board of METRO AG, Düsseldorf, and professional liability as described above was governed by the General Engagement Terms for Wirtschaftsprüfer and Wirtschaftsprüfungsgesellschaften (Allgemeine Auftragsbedingungen für Wirtschaftsprüfer und Wirtschaftsprüfungsgesellschaften) in the version dated January 1, 2017 (https://www.kpmg.de/bescheinigungen/lib/aab_english.pdf). By reading and using the information contained in this assurance report, each recipient confirms notice of the provisions contained therein including the limitation of our liability as stipulated in No. 9 and accepts the validity of the General Engagement Terms with respect to us.

Frankfurt am Main, 1 December 2021

KPMG AG
Wirtschaftsprüfungsgesellschaft
[Original German version signed by:]

1 Our engagement applied to the German version of the Combined Non-Financial Statement 2021. This text is a translation of the Independent Assurance Report issued in the German language, whereas the German text is authoritative.