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.

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.