Cellnex has implemented robust measures to promptly, independently and objectively prevent, detect, investigate and respond to allegations or incidents relating to bribery and corruption, as outlined in the Anti-Bribery, Gifts and Hospitality Policy, the Corruption Prevention Procedure, and the Policy for the Whistleblowing Channel. According to the Anti-Bribery, Gifts and Hospitality Policy, any subject person who is knowledgeable of, or suspects, a violation of Cellnex’s Anti-Bribery Management System or related policies is required to report it either directly to their hierarchical superior or through the Whistleblowing Channel, using the designated reporting mechanisms. This ensures a clear and structured approach to addressing concerns, guaranteeing that potential issues are timely flagged. The Committee of Ethics and Compliance (CEC) is entitled to independently initiate investigations if any signs suggest a possible breach of the Anti-Bribery, Gifts and Hospitality Policy or related policies. This independent approach ensures that investigations are objective and free from conflicts of interest. Additionally, Cellnex has a Corruption Prevention Procedure that sets forth the principles and standards that must be followed for combating bribery and corruption. This Procedure serves as a guide for all managers, employees, governing bodies, and third parties, detailing their expected conduct in relation to the prevention, detection, investigation, and redress of any corrupt practices. It, thus, ensures that all stakeholders are aligned with Cellnex’s ethical and legal standards.

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.