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.

The Committee of Ethics and Compliance (CEC), as an independent body within Cellnex, is entitled to initiate investigations into potential violations of the company’s policies. The CEC’s independence is critical for maintaining impartiality, ensuring that investigations are conducted objectively without interference from the management chain involved in the matter.

Outcomes from investigations conducted by the CEC or arising from reports submitted via the Whistleblowing Channel are communicated to the appropriate administrative, management and supervisory bodies, in accordance with internal procedures. The Policy for the Whistleblowing Channel and the Anti-Bribery, Gifts and Hospitality Policy define the process for reporting these outcomes, ensuring that findings are shared with relevant governance structures for review and action, as appropriate. This ensures transparency and accountability at all levels of the organisation.

Cellnex is committed to maintaining a culture of transparency and ethical conduct, ensuring that the ABMS and its policies related to anti-bribery and anti-corruption are effectively communicated to all stakeholders. These policies are accessible through various channels, including the company’s website, intranet and internal communications, with all documents made readily available online to both internal and external stakeholders.

Cellnex places a strong emphasis on training as a key component of its anti-bribery and anti-corruption framework. Mandatory ethics and compliance training is provided to all employees to ensure they are familiar with the company’s anti-bribery policies, their ethical responsibilities, and the procedures for reporting potential misconduct. In addition to the general training for all employees, specialised training is offered to key stakeholders, such as Board Members, to ensure they are equipped to address specific compliance risks. These training programs are periodically reviewed and updated to reflect the latest compliance obligations and ethical standards.

Cellnex ensures the active engagement of its administrative, management, and supervisory bodies in its anti-bribery and anti-corruption efforts, with dedicated training sessions tailored to these groups. These sessions ensure that key decision-makers are actively involved in the company’s ethics and compliance programmes, strengthening the commitment to integrity at the top levels of the organisation.

In 2024, communication about anti-corruption policies and procedures reached 100% of employees across various categories and countries. For example, Senior Management, Directors, Managers, and Coordinators/Other professionals all received 100% communication. By country, France, Italy, UK, Spain, Poland, Netherlands, Portugal, Switzerland, Denmark, Sweden, Ireland, and Austria all reported 100% communication to new employees in the reporting year. This comprehensive communication ensures that all employees are informed about the anti-corruption policies and procedures, regardless of their location or role within the company.