BASF Report 2021

Limited Assurance Report of the Independent Auditor Regarding the Integrated Non-Financial Group Statement1

To the Supervisory Board of BASF SE, Ludwigshafen am Rhein

We have performed an independent limited assurance engagement on the integrated non-financial group statement of BASF SE, Ludwigshafen am Rhein (further “Company” or “BASF”) for the period from January 1 to December 31, 2021 (further “Report”).

For the most significant non-financial steering KPIs, “Sales from Accelerator Products” and “CO2 neutral growth”, a reasonable assurance engagement has been performed.

As described in the section “Supplier Management” BASF engaged the external provider EcoVadis to perform audits on suppliers to ensure compliance with environmental, social, and corporate governance standards of the “Together for Sustainability” (TfS) initiative. The adequacy and accuracy of the conclusions from these external assessments were not part of our assurance engagement.

Management’s Responsibility

The legal representatives of BASF are responsible for the preparation of the Report in accordance with §§ 315b, 315c in conjunction with 289c to 289e HGB and with 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 (further “EU Taxonomy Regulation”) and the supplementing Delegated Acts as well as the interpretation of the wordings and terms contained in the EU Taxonomy Regulation and in the supplementing Delegated Acts by the Company as disclosed in the section “EU Taxonomy” of the Report.

This responsibility of the legal representatives includes the selection and application of appropriate methods to prepare the Report 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 Report that is free of – intended or unintended – material misstatements.

The EU Taxonomy Regulation and the supplementing Delegated Acts contain wordings and terms that are still subject to substantial uncertainties regarding their interpretation and for which not all clarifications have been published yet. Therefore, the legal representatives have included a description of their interpretation in the section “EU Taxonomy” of the Report.

They are responsible for its tenability. Due to the innate risk of diverging interpretations of vague legal concepts, the legal conformity of these interpretations is subject to uncertainty.

Practitioner’s Responsibility

It is our responsibility to express a conclusion on the Report based on our work performed within a limited assurance engagement and with reasonable assurance for the most significant non-financial steering KPIs.

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” and the International Standard on Assurance Engagements (ISAE) 3410: “Assurance Engagements on Greenhouse Gas Statements” 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 Report for the period from January 1 to December 31, 2021, has not been prepared, in all material respects, in accordance with §§ 315b and 315c in conjunction with 289c to 289e HGB and with the EU Taxonomy Regulation and the supplementing Delegated Acts as well as the interpretation of the wordings and terms contained in the EU Taxonomy Regulation and in the supplementing Delegated Acts by the legal representatives as disclosed in the section “EU Taxonomy” of the Report. 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 limited assurance engagement, we performed, amongst others, the following procedures:

  • Inquiries of personnel on group level who are responsible for the materiality analysis to get an understanding of the process for identifying material topics and respective report boundaries of BASF.
  • A risk analysis, including a media research, to identify relevant information on BASF sustainability performance in the reporting period.
  • Review of the suitability of internally developed Reporting Criteria for the quantitative disclosures.
  • Evaluation of the design and implementation of the systems and processes for the collection, processing and monitoring of disclosures on environmental, employee and social matters, respect for human rights, and combating corruption and bribery, including the consolidation of the data.
  • Inquiries of personnel on group level who are responsible for determining disclosures on concepts, due diligence processes, results and risks, the conduction of internal controls and consolidation of the disclosures.
  • Evaluation of selected internal and external documents.
  • Analytical evaluation of data and trends of quantitative disclosures which are reported by all sites on group level.
  • Evaluation of local data collection and reporting processes and reliability of reported data via a sampling survey at the sites Ludwigshafen am Rhein and Düsseldorf (Germany), Antwerp (Belgium), Moerdijk-Ellba (Netherlands), Port Arthur and Freeport (USA), Kuantan (Malaysia) as well as Yeosu (South Korea).
  • Alignment of disclosures in the integrated non-financial group statement with the respective disclosures in the consolidated financial statements and in the group management report
  • Assessment of the overall presentation of the disclosures
  • Evaluation of the process for the identification of taxonomy eligible economic activities and the corresponding disclosures in the Report.

The legal representatives have to interpret vague legal concepts in order to be able to compile the relevant disclosures according to Article 8 of the EU Taxonomy Regulation. Due to the innate risk of diverging interpretations of vague legal concepts, the legal conformity of these interpretations and, correspondingly, our assurance thereof are subject to uncertainty.

For the most significant non-financial steering KPIs “Sales from Accelerator Products” and “CO2 neutral growth”, we conducted our work in the form of a reasonable 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” and, for the KPI “CO2 neutral growth” in accordance with the International Standard on Assurance Engagements (ISAE) 3410: “Assurance Engagements on Greenhouse Gas Statements”, both published by IAASB. Accordingly, we have to comply with our professional duties and to plan and perform the assurance engagement in such a way that we, respecting the principle of materiality, reach our conclusion with a reasonable level of assurance. The choice of assurance procedures is subject to the auditor’s own judgement.

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

  • A risk analysis, including a media research, to identify relevant information on BASF sustainability performance in the reporting period in relation to the KPIs “Sales from Accelerator Products” and “CO2 neutral growth”
  • Evaluation of the design and implementation of systems and processes for the collection, processing and monitoring of disclosures, including the consolidation of the data for the KPIs “Sales from Accelerator Products” and “CO2 neutral growth”
  • Performing control-based assurance procedures to assess the design and effectiveness of internal controls used to collect and process non-financial disclosures and data, including
  • the consolidation of the data at group level for the KPIs “Sales from Accelerator Products” and “CO2 neutral growth”
  • Substantive assurance procedures using, in particular, internal and external documentation
  • Analytical evaluation of data and trends of quantitative disclosures for the KPIs “Sales from Accelerator Products” and “CO2 neutral growth” which are reported by all sites to group level for consolidation
  • Evaluation of local data collection and reporting processes and reliability of reported data via a sampling survey at the sites Ludwigshafen am Rhein and Düsseldorf (Germany), Antwerp (Belgium), Moerdijk-Ellba (Netherlands), Port Arthur and Freeport (USA), Kuantan (Malaysia) as well as Yeosu (South Korea).

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 for the limited assurance, nothing has come to our attention that causes us to believe that the integrated non-financial group statement of BASF SE for the period from January 1 to December 31, 2021 has not been prepared, in all material respects, in accordance with §§ 315b and 315c in conjunction with 289c to 289e HGB and with the EU Taxonomy Regulation and the supplementing Delegated Acts as well as the interpretation disclosed in the section “EU taxonomy” of the integrated non-financial group statement.

In our opinion the most significant non-financial steering KPIs, “Sales from Accelerator Products” and “CO2 neutral growth”, of BASF SE for the period from January 1 to December 31, 2021 have been prepared, in all material respects, in accordance with §§ 315b and 315c in conjunction with 289c to 289e HGB.

Restriction of Use/Clause on General Engagement Terms

This report is issued for purposes of the Supervisory Board of BASF SE, Ludwigshafen am Rhein, only. We assume no responsibility with regard to any third parties.

Our assignment for the Supervisory Board of BASF SE, Ludwigshafen am Rhein, and professional liability as described above is 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 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, February 22, 2022 KPMG AG

Wirtschaftsprüfungsgesellschaft [Original German version signed by:]

Glöckner Wirtschaftsprüfer [German Public Auditor]

ppa. Meldau

Glöckner
Wirtschaftsprüfer [German Public Auditor]

ppa. Meldau

1 Our engagement applied to the German version of the integrated non-financial group statement 2021. This text is a translation of the Independent Assurance Report issued in German, whereas the German text is authoritative.