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 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.