FULLTEXT DEL 4 AV 4
Årsredovisning 2025
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The Parent Company’s Management Board and members of the Supervisory Board are obliged to
ensure that the consolidated financial statements comply with the requirements specified in the
Accounting Act of 29 September 1994 (“the Accounting Act”) . Members of the Supervisory Board are
responsible for overseeing the financial reporting process.
Auditor’s responsibility for the audit of the consolidated financial statements
Our objectives are to obtain reasonable assurance about whether the consolidated financial statements
as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s
report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a
guarantee that an audit conducted in accordance with the NSA will always detect a material
misstatement when it exists. Misstatements can arise from fraud or error and are considered material if,
individually or in aggregate, they could reasonably be expected to influence economic decisions of users
taken on the basis of these consolidated financial statements.
The scope of the audit does not include an assurance on the Group’s future profitability nor the
efficiency and effectiveness of conducting its affairs by the Parent Company’s Management Board, now
or in future.
As part of an audit in accordance with NSA, we exercise professional judgement and maintain
professional scepticism throughout the audit. We also:
• identify and assess the risks of material misstatement of the consolidated financial statements, whether
due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit
evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a
material misstatement resulting from fraud is higher than for one resulting from error, as fraud may
involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control;
• obtain an understanding of internal control relevant to the audit in order to design audit procedures that
are appropriate in the circumstances, but not for the purpose of expressing an opinion on the
effectiveness of the Group’s internal control;
• evaluate the appropriateness of accounting policies used and the reasonableness of accounting
estimates and related disclosures made by the Parent Company’s Management Board;
• conclude on the appropriateness of the Parent Company’s Management Board’s use of the going
concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty
exists related to events or conditions that may cast significant doubt on the Group’s ability to continue
as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention
in our auditor’s report to the related disclosures in the consolidated financial statements or, if such
disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence
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obtained up to the date of our auditor’s report. However, future events or conditions may cause the
Group to cease to continue as a going concern;
• evaluate the overall presentation, structure and content of the consolidated financial statements,
including the disclosures, and whether the consolidated financial statements represent the underlying
transactions and events in a manner that achieves fair presentation;
• plan and perform the group audit to obtain sufficient appropriate audit evidence regarding the financial
information of the entities or business units within the Group as a basis for forming an opinion on the
consolidated financial statements. We are responsible for the direction, supervision and review of the
audit work performed for the purpose of the group audit. We remain solely responsible for our audit
opinion.
We communicate with the Audit Committee of the Parent Company regarding, among other matters, the
planned scope and timing of the audit and significant audit findings, including any significant deficiencies
in internal control that we identify during our audit.
We also provide the Audit Committee of the Parent Company with a statement that we have complied
with relevant ethical requirements regarding independence, and communicate with them all relationships
and other matters that may reasonably be thought to bear on our independence, and where applicable,
actions taken to eliminate threats or safeguards applied.
From the matters communicated to Audit Committee of the Parent Company, we determine those
matters that were of most significance in the audit of the consolidated financial statements of the current
period and are therefore the key audit matters. We describe these matters in our auditor’s report unless
law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances,
we determine that a matter should not be communicated in our report because the adverse
consequences of doing so would reasonably be expected to outweigh the public interest benefits of such
communication.
Other information, including the report on operations
Other information comprises:
• the Report on the Group’s operations for the financial year ended 31 December 2025 (“the Report on
the operations”) together with the corporate governance statement and the consolidated name of the
sustainability statement which are separate parts of the Report on the operations,
• other documents included in the Annual Report for the financial year ended 31 December 2025
(together “Other Information”).
Other information does not include the consolidated financial statements and our auditor’s report
thereon.
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Responsibility of the Management and Supervisory Board of the Parent Company
The Management Board of the Parent Company is responsible for the preparation of the Other
Information in accordance with the law.
The Parent Company’s Management Board and the members of the Supervisory Board are obliged to
ensure that the Report on the operations including its separate parts complies with the requirements of
the Accounting Act.
Statutory auditor’s responsibility
Our opinion on the consolidated financial statements does not cover the Other Information.
In connection with our audit of the consolidated financial statements, our responsibility under NSA is to
read the Other Information and, in doing so, consider whether the Other Information is materially
inconsistent with the information in the consolidated financial statements, our knowledge obtained in our
audit, or otherwise appears to be materially misstated. If, based on the work performed, we identified
a material misstatement in the Other Information, we are obliged to inform about it in our audit report.
In accordance with the requirements of the Act on Statutory Auditors, we are also obliged to issue an
opinion on whether the Report on the operations, to the extent not related to sustainability reporting, has
been prepared in accordance with the requirements of Article 49 of the Accounting Act and para. 73 of
the Regulation of the Minister of Finance dated 6 June 2025 on current and periodical information
submitted by issuers of securities and conditions for considering as equivalent the information required
under the legislation of a non-Member State (“Regulation on current information”), is consistent with
information included in consolidated financial statements and to issue a statement as to whether, in the
light of the knowledge about the Group and its environment obtained during the audit, any material
misstatements have been identified in the Report on the operations to the extent not related to
sustainability reporting, and an indication of what any such material misstatement is.
Moreover, we are obliged to issue an opinion on whether the Company Group provided the required
information in its corporate governance statement .
Statement on the Other information
We declare that, based on the knowledge of the Group and its environment obtained during our audit:
• we have nothing to report regarding identification of material misstatements in the Other information;
• we have not identified any material misstatements in the Report on the operations, to the extent not
related to sustainability reporting.
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Opinion on the Report on the operations to the extent not related to sustainability reporting
Based on the work we carried out during our audit, in our opinion, the Report on the operations, to the
extent not related to sustainability reporting:
• has been prepared in accordance with the requirements of Article 49 of the Accounting Act and para.
73 of the Regulation on current information;
• is consistent with the information in the consolidated financial statements.
Opinion on the corporate governance statement
In our opinion, in its corporate governance statement, the Company Group included information set out
in para. 72.7 (5) of the Regulation on current information. In addition, in our opinion, information
specified in paragraph 72.7 (5)(c)–(f), (h) and (i) of the said Regulation are consistent with the applicable
provisions of the law and with information included in the consolidated financial statements.
Report on other legal and regulatory requirements
Report on the compliance of the marking up of consolidated financial statements with the
requirements of the European Single Electronic Format (“ESEF”)
In connection with the audit of consolidated financial statements we have been engaged by the Parent
Company’s Management Board as part of our audit engagement letter to conduct a reasonable
assurance engagement to express an opinion whether the consolidated financial statements of the
Group as at and for the year ended 31 December 2025 prepared in the single electronic format
contained in the file named ATC-2025-12-31-1-pl.xbri (the “consolidated financial statements in the
ESEF format”) were marked up in accordance with the requirements of the article 4 of the Commission
Delegated Regulation (EU) 2019/815 of 17 December 2018 supplementing Directive 2004/109/EC of the
European Parliament and of the Council with regard to regulatory technical standards on the
specification of a single electronic reporting format (the “ESEF Regulation”).
Description of a subject matter and applicable criteria
The consolidated financial statements in the ESEF format were prepared by the Parent Company’s
Management Board to comply with the technical requirements regarding the specification of a single
electronic reporting format and marking up, which are set out in the ESEF Regulation.
The subject matter of our assurance engagement is the compliance of the marking up of consolidated
financial statements in the ESEF format with the requirements of the ESEF Regulation and the
requirements of this regulation, in our view, constitute appropriate criteria to form an opinion.
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Responsibility of the Management Board and the Supervisory Board of the Parent Company
The Parent Company’s Management Board is responsible for the preparation of the consolidated
financial statements in the ESEF format in accordance with the technical requirements regarding the
specification of a single electronic reporting format which are set out in the ESEF Regulation. This
responsibility includes the selection and application of appropriate markups in XBRL using taxonomy
specified in the ESEF Regulation. The responsibility of the Management Board of the Parent Company
also includes designing, implementing and maintaining internal controls relevant for the preparation of
the consolidated financial statements in the ESEF format which are free from material non-compliance
with the requirements of the ESEF Regulation and their marking-up in compliance with these
requirements.
Members of the Parent Company’s Supervisory Board are responsible for overseeing the financial
reporting process, which also includes the preparation of the consolidated financial statements in
accordance with the format that is compliant with legal requirements.
Our responsibility
Our objective was to express an opinion, based on the conducted reasonable assurance engagement,
whether the consolidated financial statements prepared in the ESEF format were marked up, in all
material respects, with the requirements of the ESEF Regulation.
We conducted our engagement in accordance with the National Standard on Assurance Engagements
other than Audit and Review 3001PL – “Audit of financial statements prepared in the single electronic
reporting format” (“KSUA 3001PL”) and where relevant with the National Standard on Assurance
Engagements 3000 (R) in the wording of the International Standard on Assurance Engagements 3000
(Revised) - ‘Assurance Engagements other than Audits and Reviews of Historical Financial Information’
(“KSUA 3000(R)”).
These standards require that we plan and perform procedures to obtain reasonable assurance whether
the consolidated financial statements in the ESEF format were marked up, in all material respects, in
compliance with the specified criteria.
Reasonable assurance is a high level of assurance, but it does not guarantee that the engagement
performed in accordance with KSUA 3001PL and, where relevant, in accordance with KSUA 3000 (R)
will always detect the material misstatement (significant non-compliance with the requirements).
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The selection of the procedures depends on the auditor's judgement, including the auditor's assessment
of the risk of material misstatements, whether due to fraud or error. In performing the assessments of
this risk, the auditor shall consider the internal control related to the preparation of the consolidated
financial statements in the ESEF format in order to plan appropriate procedures to provide the auditor
with sufficient evidence appropriate to the circumstances. The assessment of the functioning of the
internal control system was not carried out in order to express an opinion on the effectiveness of its
operation.
Quality management and ethical requirements
We apply the National Standard on Quality Control 1 in the wording of the International Standard on
Quality Management (PL) 1 – “Quality Management for Firms that Perform Audits or Reviews of
Financial Statements, or Other Assurance or Related Services Engagements” as issued by the
International Auditing and Assurance Standards Board and adopted by the resolution of the Council of
the Polish Agency for Audit Oversight (“NSQC 1”). In accordance with the requirements of NSQC 1, we
operate a system of quality management including documented policies or procedures regarding
compliance with ethical requirements, professional standards and applicable legal and regulatory
requirements.
When performing the engagement, we have complied with the independence and other ethical
requirements in the Code of ethics. The Code of ethics is founded on fundamental principles of integrity,
objectivity, professional competence and due care, confidentiality and professional behaviour. We also
complied with other independence and ethical requirements that apply to this assurance engagement in
Poland.
Summary of the work performed
Our planned and performed procedures were aimed at obtaining reasonable assurance whether the
consolidated financial statements in the ESEF format were marked-up, in all material respects, in
compliance with the applicable requirements. Our procedures included in particular:
• obtaining an understanding of the process of preparation of the consolidated financial statements in the
ESEF format, including the process of selection and application by the Group of the XBRL tags and
ensuring the compliance with the ESEF Regulation, including understanding the mechanism of the
internal control system related to this process;
• reconciliation, on a selected sample, of the marked-up information contained in the consolidated
financial statements in the ESEF format to the audited consolidated financial statements;
• evaluating of compliance with the technical standards regarding the specification of a single electronic
reporting format, including the use of XHTML, using a specialised IT tool/and with the support of an IT
expert assessment;
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• evaluating the completeness of marking up the consolidated financial statements in the ESEF format
using the XBRL tags;
• evaluating the appropriateness of the use of XBRL tags selected from the taxonomy defined in the
ESEF Regulation and whether the extension markups were used appropriately where no suitable
element in taxonomy defined in the ESEF Regulation has been identified;
• evaluating the appropriateness of anchoring of the extension elements to the ESEF taxonomy from the
ESEF regulation;
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our
opinion.
Opinion
In our opinion, based on the procedures performed, the consolidated financial statements in the ESEF
format were marked-up, in all material respects, in compliance with the requirements of the ESEF
Regulation.
Statement on the provision of non-audit services
To the best of our knowledge and belief, we declare that the non-audit services that we provided to the
Parent Company and its parent and its controlled entities within the European Union are in accordance
with the applicable laws and regulations in Poland and that we have not provided non-audit services that
are prohibited under Article 5(1) of the EU regulation and Article 136 of the Act on Statutory Auditors.
The non-audit services which we have provided to the Parent Company and its controlled entities during
the period from the beginning of the audited period to the date of issuing this report are disclosed in the
Report on the operations.
In the period from the beginning of the audited period to the date of issuing this report, we did not
provide the Parent Company and its controlled entities with services other than audit of the financial
statements.
Appointment
We were first appointed to audit the annual consolidated financial statements of the Group by resolution
of the Supervisory Board of the Parent Company dated 22 February 2023 and re-appointed by
resolution dated 6 August 2025. We have been auditing the Group’s consolidated financial statements
without interruption since the financial year ended 31 December 2023, i.e. for 3 consecutive years.
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The Key Statutory Auditor responsible for the audit on behalf of PricewaterhouseCoopers Polska spółka
z ograniczoną odpowiedzialnością Audyt sp.k., a company entered on the list of audit firms with the
number 144., is Krzysztof Zech.
Original report is signed in Polish
Krzysztof Zech
Key Statutory Auditor
No. in the registry: 13917
Poznań, 21 April 2026
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Translation note:
This version of our report is a translation from the original, which was prepared in Polish. All possible
care has been taken to ensure that the translation is an accurate representation of the original. However,
in all matters of interpretation of information, views or opinions, the original language version of our report
takes precedence over this translation.
1
PricewaterhouseCoopers Polska spółka z ograniczoną
odpowiedzialnością Audyt sp.k., ul. Polna 11, 00-633 Warsaw,
Poland, T: +48 (22) 746 4000, F: +48 (22) 746 4040
PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt sp.k. with registered
office at ul. Polna 11, 00-633 Warsaw, entered into National Court Register by the District Court for the
Capital City of Warsaw, XII Commercial Division of the National Court Register under KRS No
0000750050, Tax ID No (NIP) 5260210228.
www.pwc.pl
Independent statutory auditor's limited assurance
report on the sustainability statement
To the Shareholders’ Meeting and the Supervisory Board of Arctic Paper S.A.
Opinion
We have conducted a limited assurance engagement on the sustainability reporting of capital group
prepared by Arctic Paper S.A. (the „Company”) as of 31 December 2025 and for the year then ended
and included in chapter Sustainability reporting of the Arctic Paper SA Management Board’s Report
2025 (the “Sustainability statement of the capital group”).
Based on the procedures we have performed and the evidence we have obtained, nothing has come to
our attention that causes us to believe that:
the Sustainability statement of the capital group is not compliant, in all material respects, with
Chapter 6c of the Accounting Act of 29 September 1994 (the “Accounting Act”), as well as with the
European Sustainability Reporting Standards (the “ESRS”);
the materiality assessment process conducted by the Company to identify information included in
the Sustainability statement of the capital group (“Materiality Assessment Process”) is not compliant,
in all material respects, with the ESRS;
the Sustainability statement of the capital group is not compliant, in all material respects, with the
reporting requirements set out in Article 8 of the 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, amending Regulation (EU) 2019/2088 (the “Taxonomy Regulation”).
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Basis for opinion
We conducted our limited assurance engagement in accordance with National Standard on Assurance
Services for Sustainability Reporting 3002PL - Limited assurance engagement on the sustainability
statement (the “NSAE 3002PL”) and, where appropriate, with National Standard on Assurance
Engagements Other than Audits and Reviews 3000 (R) in the wording of International Standard on
Assurance Engagements 3000 (Revised) - Assurance Engagements Other than Audits or Reviews of
Historical Financial Information (the “NSAE 3000 (R)”) adopted by the resolutions of the National Board
of Statutory Auditors.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our
opinion. Our responsibility under NSAE 3002PL and, where applicable, NSAE 3000(R) is further
described in the Responsibilities of statutory auditor providing the sustainability statement assurance
section.
Our independence and quality management
We have complied with the independence requirements and other ethical requirements set out in the
“Handbook of the International Code of Ethics for Professional Accountants (including International
Independence Standards)” (“Code of ethics”) adopted by resolution of the National Board of Statutory
Auditors, which is based on the fundamental principles of integrity, objectivity, professional competence
and due care, confidentiality, and professional behavior, as well as with the requirements contained in
the Act of 11 May 2017 on Statutory Auditors, Audit Firms, and Public Oversight (the “Act on Statutory
Auditors, Audit Firms and Public Oversight”) and in EU Regulation No. 537/2014 of 16 April 2014 on
specific requirements regarding statutory audit of public interest entities. We have fulfilled other ethical
obligations in accordance with the aforementioned regulations and the Code of ethics.
Our firm applies the National Quality Control Standard 1 in the wording of the International Standard on
Quality Management (PL) 1 – Quality Management for Companies that Perform Audits or Reviews of
Financial Statements, or Other Assurance or Related Services Engagements issued by the International
Auditing and Assurance Standards Board and adopted by the resolution of the Council of the Polish
Agency for Audit Oversight, as well as the provisions of the Act on Statutory Auditors, Audit Firms and
Public Oversight. This standard requires us to design, implement, and operate a system of quality
management, including policies or procedures regarding compliance with ethical requirements,
professional standards, and applicable legal and regulatory requirements.
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Responsibilities for the Sustainability statement of the capital
group
The management of the Company is responsible for designing and conducting the Materiality
Assessment Process in accordance with the ESRS to identify information included in the Sustainability
statement of the capital group in accordance with the ESRS and for disclosing this process in chapter 1.
General Information to the Sustainability statement of the capital group. These responsibilities include,
among others:
understanding the context in which the Group’s activities and business relationships take place and
developing an understanding of its affected stakeholders;
the identification of the actual and potential impacts (both negative and positive) related to
sustainability matters, as well as risks and opportunities that affect, or could reasonably be expected
to affect, the Group’s financial position, financial performance, cash flows, access to finance or cost
of capital over the short-, medium-, or long-term;
the assessment of the materiality of the identified impacts, risks and opportunities related to
sustainability matters by selecting and applying appropriate thresholds; and
making assumptions that are reasonable in the circumstances.
Management of the Company is further responsible for the preparation of the Sustainability statement of
the capital group in accordance with Chapter 6c of the Accounting Act, including, among others, the
following;
compliance with the ESRS;
compliance of the Sustainability statement of the capital group, including the disclosures in chapter
2. Environment-related information with Article 8 of the Taxonomy Regulation;
designing, implementing, and maintaining internal control that the Company's management
determines is necessary to enable the preparation of the Sustainability statement of the capital
group that is free from material misstatements, whether due to fraud or error; and
the selection and application of appropriate reporting methods of the Sustainability statement of the
capital group and making assumptions and estimates that are reasonable in the circumstances.
The Supervisory Board of the Company is responsible for overseeing the reporting process of the
Sustainability statement of the capital group.
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Inherent limitations in preparing the Sustainability statement of the capital
group
Greenhouse gas emissions quantification is subject to inherent uncertainty because of incomplete
scientific knowledge used to determine emissions factors and the values needed to combine emissions
of different gases.
In reporting forward-looking information in accordance with the ESRS, the management of the Company
is required to prepare the forward-looking information on the basis of disclosed assumptions about
events that may occur in the future and possible future actions by the Group. Actual outcomes are likely
to be different since anticipated events frequently do not occur as expected.
Responsibilities of statutory auditor providing the sustainability
statement assurance
Our objectives are to plan and perform the assurance engagement to obtain limited assurance about
whether the Sustainability statement of the capital group is free from material misstatements, whether
due to fraud or error, and to issue a limited assurance report on the Sustainability statement of the
capital group that includes our opinion. Misstatements can arise from fraud or error and are considered
material if, individually or in the aggregate, they could reasonably be expected to influence decisions of
users taken on the basis of the Sustainability statement of the capital group as a whole.
As part of a limited assurance engagement in accordance with NSAE 3002PL and NSAE 3000 (R), we
exercise professional judgement and maintain professional scepticism throughout the engagement.
Our responsibilities in respect of the Sustainability statement of the capital group, in relation to the
Materiality Assessment Process, include:
obtaining an understanding of the Materiality Assessment Process, but not for the purpose of
providing a conclusion on the effectiveness of the Materiality Assessment Process, including the
outcome of the Materiality Assessment Process;
considering whether the information identified addresses the applicable disclosure requirements of
the ESRS; and
designing and performing procedures to evaluate whether the Materiality Assessment Process is
consistent with the Company’s description of its Materiality Assessment Process set out in chapter 1.
General Information to the Sustainability statement of the capital group.
Our other responsibilities in respect of the Sustainability statement of the capital group include:
identifying where material misstatements are likely to arise, whether due to fraud or error; and
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designing and performing procedures responsive to where material misstatements are likely to arise
in the Sustainability statement of the capital group. The risk of not detecting a material misstatement
resulting from fraud is higher than for one resulting from error, as fraud may involve collusion,
forgery, intentional omissions, misrepresentations, or the override of internal control.
Summary of the work performed
A limited assurance engagement involves performing procedures to obtain evidence about the
Sustainability statement of the capital group. 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 in a limited assurance engagement is substantially lower
than the assurance that would have been obtained had a reasonable assurance engagement been
performed.
The nature, timing and extent of procedures selected depend on professional judgement, including the
identification of disclosures where material misstatements are likely to arise in the Sustainability
statement of the capital group, whether due to fraud or error.
In conducting our limited assurance engagement, with respect to the Materiality Assessment Process,
we:
obtained an understanding of the Materiality Assessment Process by:
− performing inquiries to understand the sources of the information used by management (e.g.,
stakeholder engagement, business plans and strategy documents);
− reviewing the Company’s internal documentation of its Materiality Assessment Process; and
evaluated whether the evidence obtained from our procedures with respect to the Materiality
Assessment Process implemented by the Company was consistent with the description of the
Materiality Assessment Process set out in chapter 1. General Information to the Sustainability
statement of the capital group.
In conducting our limited assurance engagement, with respect to the Sustainability statement of the
capital group, we:
obtained an understanding of the reporting process relevant to the preparation of the Sustainability
statement of the capital group by obtaining understanding of the Group’s control environment,
processes, and information system relevant to the preparation of the Sustainability statement of the
capital group, but not for the purpose of expressing an opinion on the effectiveness of the Group’s
internal control;
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evaluated whether the information identified by the Materiality Assessment Process is included in the
Sustainability statement of the capital group;
evaluated whether the structure and the presentation of the Sustainability statement of the capital
group is in accordance with the ESRS;
performed inquiries of the Company’s employees involved in the preparation of the Sustainability
statement of the capital group and analytical procedures on selected information in the Sustainability
statement of the capital group;
performed substantive assurance procedures on selected information in the Sustainability statement
of the capital group;
where applicable, compared disclosures in the Sustainability statement of the capital group with the
corresponding disclosures in the consolidated financial statements and the management report of
the Group;
evaluated the methods for developing estimates and forward-looking information;
obtained an understanding of the Company's process to identify taxonomy-eligible and taxonomy-
aligned economic activities and the corresponding disclosures in the Sustainability statement of the
capital group.
Acting on behalf of PricewaterhouseCoopers Polska spółka z ograniczoną odpowiedzialnością Audyt
sp.k., a company registered on the list of audit firms under number 144,
Original report is signed in Polish language
Piotr Kocot
Key Statutory Auditor providing the sustainability statement assurance
No. in the registry 12637
Warsaw, 21 April 2026
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Kostrzyn nad Odra, April 21st 2026 EVALUATION BY THE SUPERVISORY BOARD OF ARCTIC PAPER S.A. OF THE FINANCIAL STATEMENTS OF ARCTIC PAPER S.A. AND CONSOLIDATED FINANCIAL STATEMENTS OF ARCTIC PAPER GROUP FOR THE FINANCIAL YEAR 2025 AND MANAGEMENT BOARD REPORT ON THE ACTIVITIES OF THE ARCTIC PAPER GROUP AND ARCTIC PAPER S.A. IN 2025. Legal basis: Article 72.1.16 and article 73.1.14 of the Regulation of the Minister of Finance of 6 June 2025 on current and periodic information provided by issuers of securities and on conditions under which information required by legal regulations of a third country may be recognised as equivalent(Dz. U. z 2025 r. pos. 755). The Supervisory Board of Arctic Paper S.A. ("the Company") after review of the financial statements of Arctic Paper S.A. for the financial year ended December 31, 2025, as well as with the report of an independent certified auditor on the audit of the Company's annual standalone financial statements for the financial year ended December 31, 2024, prepared by , states that the financial statements presented by the Management Board have been prepared correctly in terms of substance and form, in accordance with the books and documents, as well as with the facts, and accurately reflects the financial result and assets of the Company in the financial year 2025. The Supervisory Board of Arctic Paper S.A. after review of the consolidated financial statements of the Arctic Paper Group for the financial year ended December 31, 2025, as well as with the report of an independent auditor on the audit of the annual consolidated financial statements for the financial year ended December 31, 2025, prepared by , states that the consolidated financial statements of Arctic Paper Group has been prepared correctly in terms of substance and form, in accordance with the books and documents, as well as with the facts, and accurately reflects the financial result and assets of the Arctic Paper Group in the financial year 2025. The Supervisory Board of Arctic Paper S.A., after review of the reports of the Management Board of Arctic Paper S.A. on the activities of the Arctic Paper Group and the Company for 2024, states that reports have been prepared in accordance with the relevant applicable regulations regarding the reports on the activities and is in accordance with the books, documents and the actual state. The above evaluation of the Supervisory Board of Arctic Paper S.A. was issued based on the recommendation of the Audit Committee of Arctic Paper S.A. expressed in Resolution No. 01/04/2026 of April 14th, 2026. Chairman of the Supervisory Board of Arctic Paper S.A. Per Lundeen
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Kostrzyn nad Odra, April 21st 2026 Statement of the Supervisory Board of Arctic Paper S.A. on the functioning of the Audit Committee in the financial year ended on 31 December 2025 The Supervisory Board of Arctic Paper S.A. hereby represents that it complies with the regulations concerning the appointment, composition, and functioning of the Audit Committee, including the regulations on satisfaction of the independence criteria by its members, the requirements with regard to having knowledge and skills relating to the industry in which Arctic Paper S.A. operates, as well as accounting or auditing of financial statements. The Audit Committee was performing the tasks specified in the applicable regulations. Chairman of the Supervisory Board of Arctic Paper S.A. Per Lundeen
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Kostrzyn nad Odra, April 21st 2026 Statement of the Supervisory Board of Arctic Paper S.A. on selection of an audit firm conducting an audit of the financial statements On 6thof August 2025, the Supervisory Board of Arctic Paper S.A., by way of resolution, selected audit firm to audit the Company's financial statements for the financial years 2025 - 2026. The selection of the audit firm by the Supervisory Board was based on the Audit Committee’s recommendation. The Audit Committee’s recommendation was made pursuant to the selection procedure in line with the “Policy and procedure of selecting an audit firm to conduct a statutory and voluntary audit of consolidated and separate financial statements of Arctic Paper S.A. with its ”. Audit firm , entities related to this audit firm, and members of a network of the audit firm did not provide permitted non-audit services for the issuer during the audited period. The audit firm and members of the audit team complied with the criteria to issue an impartial and independent report on the audit of the annual consolidated financial statements of the Company for the financial year ended on 31 December 2025, in compliance with the applicable laws, professional standards, and the principles of professional conduct. Furthermore, the Supervisory Board informs that the applicable laws with regard to a change of the audit firm and the key statutory auditor, as well as mandatory periods of grace have been complied with. The Arctic Paper Group has a policy of selecting an audit firm and a policy of rendering services for the Group by an audit firm, an entity related to the audit firm, or a member of its network, that are non-audit services, including services released from the prohibition of the provision of services by an audit firm. The above statement of the Supervisory Board of Arctic Paper S.A. was issued based on the recommendation of the Audit Committee of Arctic Paper S.A. expressed in Resolution No. 01/04/2026 of April 14th , 2026. Chairman of the Supervisory Board of Arctic Paper S.A. Per Lundeen