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 maintains a robust Disciplinary System that provides a clear framework to address any future breaches of anti-bribery and anti-corruption standards and defines the steps that the company would take to sanction these. The System applies not only to the direct perpetrators of breaches but also to those who induce, cooperate, or assist in these non-compliant activities. Depending on the severity of the breach, disciplinary actions may include verbal or written warnings, suspension of salary and employment, or dismissal of employees or members of the Board of Directors. For third parties maintaining commercial relationships with Cellnex, violations could result in the termination of contracts or business relationships. These sanctions are always applied proportionally, under proper justification and in strict compliance with labour laws and other applicable regulations. In addition, Cellnex's Anti-Bribery, Gifts and Hospitality Policy and the Corruption Prevention Procedure complement the Disciplinary System by establishing clear guidelines for preventing, detecting, investigating, and addressing corrupt practices.