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 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.