Cellnex’s Whistleblowing Channel allows both internal and external stakeholders, including any third party, wishing to report concerns about unlawful behaviour or infringements that disobey the current legislation and/or other internal regulations within the company. The reporting mechanisms are accessible via multiple channels, including the Cellnex Intranet, email, mailing address and telephone, ensuring that individuals can easily raise concerns from anywhere in the world. The Whistleblowing Channel is managed by an independent expert third party, PricewaterhouseCoopers (PwC), acting as Channel Manager and ensuring confidentiality and impartiality of the process. The Channel Manager receives the initial communication and guarantees that it is transferred to the Committee of Ethics and Compliance (CEC) in due time. The CEC as the decision-making body, will investigate and adopt a final resolution that closes the procedure. The Channel Manager will then be responsible for communicating the resolution to the whistleblower in due time and form. To promote the use of the Channel, Cellnex has implemented extensive training, communication and awareness initiatives. These efforts ensure that all employees are fully informed about the existence, purpose, and proper use of the Whistleblowing Channel. In addition, employees receive training on the process of submitting communications and on the importance of raising ethical issues promptly. The commitment to training extends to the staff receiving the reports, who are prepared to handle concerns professionally, following legal guidelines and internal protocols.

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.