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 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.