Cellnex is committed to fostering a culture of integrity and ethical business conduct through a comprehensive training policy. For this reason, it has implemented mandatory training programmes for all employees, which cover key topics such as ethical behaviour, compliance standards and legal obligations. Training is delivered through a combination of in-person sessions, e-learning modules, and periodic refresher courses to ensure ongoing awareness and alignment with Cellnex’s policies. To assess the effectiveness of these programmes, the company regularly conducts tests, gathers feedback through surveys, and performs compliance reviews.

Cellnex identifies activities and functions that are especially exposed to bribery and corruption risks through regular risk assessments. Based on these, the company implements targeted training programmes, apply strict controls, and conduct frequent reviews to manage these risks effectively. This approach ensures that the areas that are especially vulnerable to unethical conducts are continuously monitored, and that proper preventive measures are in place to mitigate potential issues related to bribery and corruption.

Cellnex adopts a zero-tolerance policy for retaliation. The company safeguards whistleblowers by ensuring that no individual who reports concerns in good faith will face retaliation. If any whistleblower perceives that they have been subjected to retaliation, they are encouraged to report this immediately, and the company will take appropriate action to investigate and address the issue. All whistleblowers are guaranteed confidentiality and protection in line with applicable laws, including the EU Whistleblower Directive (2019/1937).

Cellnex has various policies and procedures in place across its different geographies to prevent late payments, particularly to SMEs. These policies are tailored to meet local needs and ensure timely payments to vendors, thus avoiding payment delays that could negatively impact business relationships.

Below is an overview of the policies and practices implemented in different countries:

• France: Payment processes are supported by proactive measures, such as maintaining regular communication with key stakeholders to monitor and address unpaid invoices. Aged customer balances are regularly reviewed to ensure visibility and support recovery actions. The adoption of streamlined tools has also enhanced efficiency and improved payment timelines.

• Italy: Payment terms are reviewed during the purchasing process to ensure alignment with contractual or agreed-upon conditions before approving purchase orders. This proactive approach helps on minimizing the risk of discrepancies and delays, even in the absence of formal policies.

• The United Kingdom: New suppliers are provided with terms and conditions, and as long as these are followed, payments are made according to the agreed schedule.

• Spain: Payment dates for invoices are set based on the conditions approved by the Purchasing Department. Every month, the Administration Department is provided with a list of scheduled payments, which is cross-checked with SAP to ensure payments are made on time. The maximum payment period is 60 days after the specified payment date.

• Poland: Payments to suppliers are managed through regular schedules to avoid delays, with approvals coordinated by the Finance Administration Team prior to processing. Systems are in place to accommodate urgent payments in exceptional circumstances, ensuring continuity of operations.

• The Netherlands: Payment processes are guided by an established policy, with the local team and external partners collaborating to prepare, review, and approve payment proposals. The approval process involves multiple representatives at both local and corporate levels, ensuring compliance and control. Exceptions and urgent payments are handled through a dedicated system, and regular monitoring ensures continuous improvement and oversight.

• Switzerland: Payments are aligned with the corporate payment calendar, ensuring regular and systematic processing. Provisions are made for handling urgent and overdue payments as needed, maintaining operational consistency and financial discipline.

• Denmark and Sweden: Both countries have local payment policies in place to manage payments to all vendors, ensuring that payments are made timely.

• Austria: Corporate rules and policies were followed to prevent late payments. The accounting department monitored invoices and payment flows, sent reminders to ensure that payments are processed within the invoice timeframe, and maintained regular invoicing cycles to anticipate potential issues.

Cellnex aims to establish enduring partnerships with its suppliers on the basis of mutual benefits and trust, thus fostering robust business relationships. In a constantly evolving world, the collaboration of its suppliers is crucial for the company to effectively address market demands. In this respect, Cellnex regularly updates its suppliers on new projects and encourages their cooperation. It is essential for the company to ensure that its suppliers are aware of its corporate policies and values, and that compliance with all of them is enforced. This collaborative approach ensures that Cellnex's supplier relationships are mutually beneficial and focused on long-term success, while also managing any potential risks.

The procurement process is key for Cellnex. For this reason, the company has established and actively promotes an action guide for the procurement process that goes beyond price, product and/or service quality, but that also considers social, ethical, environmental, and privacy aspects regarding the performance of its suppliers. This reflects the company's proactive approach to managing its supply chain impacts and risks in line with sustainability principles. By integrating these factors into procurement practices, Cellnex ensures that its supplier base contributes positively to its broader ESG objectives.

The company's supplier relationship model relies on a collaborative approach between the requesting departments and the procurement team, working jointly to achieve optimal procurement practices. In many cases, relationships with suppliers are built upon years of cooperation between Cellnex staff and its suppliers. This model of collaboration reflects the company's long-term approach to managing supplier relationships, ensuring that risks are mitigated and mutual benefits are prioritised.

Through this close partnership, Cellnex is better positioned to address challenges and opportunities, enhancing both supplier performance and business outcomes.

The company also prioritises a collaborative approach to supplier management when focusing on efficiency and innovation. By implementing a Sustainability Linked Confirming, tied to CDP scores, Cellnex incentives sustainable practices among its suppliers.

This initiative is not only aligned with the company's ESG objectives, but also fosters long-term, value-driven partnerships.

Cellnex integrated ESG and risk management into its supply chain in 2022, in accordance with its ESG Master Plan. This involved a collaborative effort of various departments, such as Health & Safety, Legal, Security, ESG, Environment and Climate Change, Quality and Procurement in order to define a comprehensive model.

The collaboration between these departments was centred on risk definition, supplier's categorisation, and on the configuration of a model that could include ESG questions and risk management in the following processes: supplier onboarding, qualification, sourcing, and contracts, and evaluation.

This approach ensures the mitigation of potential risks on the supply chain and fosters its alignment with Cellnex's ESG objectives.

Additionally, Cellnex categorises its suppliers into three tiers based on the company's annual expenditure on purchases and on the criticality of the services that they provide.

• Tier A (critical suppliers), includes suppliers with annual purchases over €5,000,000, or those delivering critical services for business continuity.
• Tier B, includes suppliers with annual purchases between €500,000 and €5,000,000.
• Tier C, includes suppliers with annual purchases below €500,000.

In 2024, the group qualified its critical suppliers, covering 65% of the total spent.

In this regard, we can highlight Cellnex Italy, since strategically extends its commitment to values and a sustainable culture across the entire supply chain. The company seamlessly integrates supplier evaluation, selection and monitoring with the assessment of ESG requirements, thus reinforcing its dedication to sustainability.

Cellnex's selection of suppliers for audit aligns with the ESG risk level, considering factors such as the supply's nature, certifications, dedication to social and environmental responsibility, and an assessment of the supplier's environmental, health and safety, and service quality.

In 2024, Cellnex invested €26,000 in the CDP Supply Chain programme to promote transparency and encourage collaboration with suppliers to reduce emissions. The company invited a total of 272 suppliers, of which 81% responded. In addition, Cellnex offered a Supplier Support Programme with an investment of €10,100 to improve the quality of emissions data provided by its partners.

The Anti-Bribery, Gifts and Hospitality Policy works in tandem with the Corruption Prevention Procedure (CPP) to establish clear standards for preventing bribery and managing gifts, hospitality, and similar benefits. Employees and stakeholders are required to report any concerns or violations of the Policy either to their hierarchical superior or directly through Cellnex’s Whistleblowing Channel. This system ensures all concerns are treated with the utmost priority and addressed promptly. The CPP is aligned with international best practices, including the ISO 37001, and outlines the principles and standards that all managers, employees, governing bodies, and third parties must follow to prevent, detect, and address corrupt practices. This Procedure is regularly updated to ensure compliance with the evolving legal and regulatory requirements. The CPP provides a clear framework for identifying, investigating, and addressing potential bribery or corruption cases within the company, ensuring accountability at all levels.

The Committee of Ethics and Compliance (CEC), as an independent body within Cellnex, is entitled to initiate investigations into potential violations of the company’s policies. The CEC’s independence is critical for maintaining impartiality, ensuring that investigations are conducted objectively without interference from the management chain involved in the matter.

Outcomes from investigations conducted by the CEC or arising from reports submitted via the Whistleblowing Channel are communicated to the appropriate administrative, management and supervisory bodies, in accordance with internal procedures. The Policy for the Whistleblowing Channel and the Anti-Bribery, Gifts and Hospitality Policy define the process for reporting these outcomes, ensuring that findings are shared with relevant governance structures for review and action, as appropriate. This ensures transparency and accountability at all levels of the organisation.

Cellnex is committed to maintaining a culture of transparency and ethical conduct, ensuring that the ABMS and its policies related to anti-bribery and anti-corruption are effectively communicated to all stakeholders. These policies are accessible through various channels, including the company’s website, intranet and internal communications, with all documents made readily available online to both internal and external stakeholders.