Independent assurance report to Smurfit Kappa plc

Introduction
We were engaged by the management of Smurfit Kappa Group plc (SKG) to provide assurance on the 2009 data for selected environmental indicators in the SKG Sustainable Development Report 2009 (further referred to as the ‘Report’). The Report, including the identification of material issues, is the responsibility of the Company’s management. Our responsibility is to issue an independent assurance report.

Our engagement was designed to provide limited assurance on whether the 2009 data for the following environmental indicators are, in all material respects, presented in accordance with SKG’s reporting principles:

• Energy consumption: total electricity and total fuels (page 57);
• CO2 emissions: CO2 fossil direct, CO2 fossil indirect and CO2 biogenic (page 57);
• Water withdrawal: total water withdrawal (page 57);
• Water discharge: Chemical Oxygen Demand (COD) and Total Suspended Solids (page 57);
• Fibre certification (page 18 and pages 50-51).

The data for these indicators are shown by an asterisk (*) on the pages mentioned above, together with the text ‘Within KPMG assurance scope’.

Procedures performed to obtain a limited level of assurance are aimed at determining the plausibility of information and are less extensive than those for a reasonable level of assurance.

Reporting criteria and assurance standard
SKG applies the Sustainability Reporting Guidelines of the Global Reporting Initiative (G3) together with internal corporate guidelines, as detailed in approach to sustainability reporting in the section Scope of the Report on page 7. It is important to view the performance data within the assurance scope in the context of this explanatory information. We believe that these criteria are suitable in view of the purpose of our assurance engagement.

We conducted our engagement in accordance with the International Standard for Assurance Engagements (ISAE) 3000: Assurance Engagements other than Audits or Reviews of Historical Financial Information, issued by the International Auditing and Assurance Standards Board. This standard requires, amongst others, that the assurance team members possess the specific knowledge, skills and professional competencies needed to understand and review the information and that they comply with ethical requirements, including independence requirements.

Work undertaken
We made inquiries, primarily of persons responsible for the preparation of data for the selected environmental indicators, and we applied analytical and other evidence gathering procedures, as appropriate. These procedures included:

• Reviewed the systems and processes for collecting and processing the information for the selected environmental indicators as well as internal controls at corporate level relating to this information.
• Interviewed relevant staff at corporate level responsible for the reported information on the selected indicators.
• Reviewed the data submitted by all sites for central aggregation for the selected environmental indicators, together with an assessment of the indicator calculations and the quality of the data validation process at corporate level.
• Reviewed the reliability of the local data and the design and implementation of local validation processes at four sites: Facture (France), Herzberg am Harz (Germany), Roermond (the Netherlands) and Cali (Colombia).

Conclusion
Based on the procedures performed, as described above, nothing came to our attention to indicate that the 2009 data for the selected indicators are not, in all material respects, presented in accordance with the reporting criteria, as described in the section Scope of the Report on page 7.

Other observations
Without affecting the conclusions presented above, we would like to draw the readers’ attention to the following:
The environmental data management systems at the operations of SKG can be further enhanced in terms of documenting data management procedures and recording the results of these procedures, such as the data review by local management. We recommend improving the local environmental data management systems to further strengthen the monitoring of performance against sustainability goals.

Amstelveen, 18 June 2010
KPMG Sustainability

W.J. Bartels
Partner