Appendix

Independent Assurance Statement to Primark Limited

Scope 

We have been engaged by Primark Limited (“Primark”) to perform a ‘limited assurance engagement,’ as defined by International Standards on Assurance Engagements, here after referred to as the Engagement, to report on selected non-financial indicators as listed below in Table 1 (the “Subject Matter”) for the year ended 31 July 2025 (or for the 52 weeks ended 13 September 2025 for metrics marked with an asterisk, or year ending 31 December 2024 for metrics marked with an ^) contained in the Primark Sustainability and Ethics Progress Report 2024/2025 and in the ‘Social Audit Performance Statement’ subsection of the ‘Reports’ section of Primark’s corporate website (referred to as “the Primark Reports”).

The Subject Matter, as listed in Table 1, is also marked with a Δ symbol in the Primark Reports.

Table 1: List of selected non-financial indicators

Other than as described in the preceding paragraph, which sets out the scope of our engagement, we did not perform assurance procedures on the remaining information included in the Primark Report, and accordingly, we do not express a conclusion on this information.

Criteria applied by Primark 

In preparing the Subject Matter, Primark has applied the reporting criteria detailed in the ‘About our Reporting’ appendix of the Primark Sustainability and Ethics Progress Report 2024/2025 (the “Criteria”).

Primark’s responsibilities

Primark’s management is responsible for selecting the Criteria, and for presenting the Subject Matter in accordance with that Criteria, in all material respects. This responsibility includes establishing and maintaining internal controls, maintaining adequate records and making estimates that are relevant to the preparation of the subject matter, such that it is free from material misstatement, whether due to fraud or error.

EY’s responsibilities

Our responsibility is to express a conclusion on the presentation of the Subject Matter based on the evidence we have obtained.

We conducted our Engagement in accordance with the International Standard for Assurance Engagements Other Than Audits or Reviews of Historical Financial Information (‘ISAE 3000 Revised’), and the International Standard for Assurance Engagements on Greenhouse Gas Statements (‘ISAE 3410’), and the terms of reference for this Engagement as agreed with Primark on 28 May 2025, and subsequently amended on 26 September 2025 and 18 November 2025. Those standards require that we plan and perform our engagement to express a conclusion on whether we are aware of any material modifications that need to be made to the Subject Matter in order for it to be in accordance with the Criteria, and to issue a report. The nature, timing, and extent of the procedures selected depend on our judgment, including an assessment of the risk of material misstatement, whether due to fraud or error.

We believe that the evidence obtained is sufficient and appropriate to provide a basis for our limited assurance conclusions.

Our independence and quality management

We have maintained our independence and confirm that we have met the requirements of the Code of Ethics for Professional Accountants issued by the International Ethics Standards Board for Accountants and have the required competencies and experience to conduct this assurance engagement.

EY also applies International Standard on Quality Management 1, Quality Management for Firms that Perform Audit or Reviews of Financial Statements, or Other Assurance or Related Services Engagements, which requires that we 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.

Description of procedures performed  

Procedures performed in a limited assurance engagement vary in nature and timing, 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. Our procedures were designed to obtain a limited level of assurance on which to base our conclusion and do not provide all the evidence that would be required to provide a reasonable level of assurance.

Although we considered the effectiveness of management’s internal controls when determining the nature and extent of our procedures, our assurance engagement was not designed to provide assurance on internal controls. Our procedures did not include testing controls or performing procedures relating to checking aggregation or calculation of data within IT systems.

The Greenhouse Gas (GHG) quantification process is subject to scientific uncertainty, which arises because of incomplete scientific knowledge about the measurement of GHGs. Additionally, GHG procedures are subject to estimation (or measurement) uncertainty resulting from the measurement and calculation processes used to quantify emissions within the bounds existing scientific knowledge. 

A limited assurance engagement consists of making enquiries, primarily of persons responsible for preparing the Subject Matter and related information and applying analytical and other appropriate procedures. 

The procedures we performed were based on our professional judgement and included the steps outlined below:

1. Engaging with selected members of Primark's leadership and senior management to discuss the governance structures around the preparation of the Subject Matter, and the progress made during the reporting year.
2. Meeting with key data owners to understand the processes for recording, aggregating, calculating, and reporting the Subject Matter.
3. Undertaking analytical procedures on the Subject Matter, to:
   1. assess the accuracy and completeness, and consistency with the established Criteria; and
   2. make enquiries of management to obtain explanations for any significant differences we identified.
4. Testing, on a sample basis, underlying source information to check the accuracy of the Subject Matter.
5. Recalculating computations performed by management to assess the accuracy of data aggregation for reporting purposes.
6. For the audit rating percentages, on a sample basis, agreeing the reporting audit grade back to management’s records and the established Criteria. We did not reperform any underlying audits to determine if the gradings applied were appropriate nor did we perform any procedures to assess the appropriateness of managements’ judgement in determining the grading. Our work does not provide any assurance over the appropriateness of the gradings determined by management

We also performed such other procedures as we considered necessary in the circumstances.

Conclusion

Based on our procedures and the evidence obtained, we are not aware of any material modifications that should be made to the Subject Matter for the year ended 31st July 2025 (or for the 52 weeks ended 14 September 2025 for metrics marked with an asterisk, or year ending 31 December 2024 for metrics marked with an ^), in order for it to be in accordance with the Criteria.

Use of our assurance statement

We disclaim any assumption of responsibility for any reliance on this assurance statement or its conclusions to any persons other than Primark, or for any purpose other than that for which it was prepared.

Accordingly, we accept no liability whatsoever, whether in contract, tort or otherwise, to any third party for any consequences of the use or misuse of this assurance statement or its conclusions.

Ernst & Young 

26 November 2025
Dublin Ireland

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