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 continuously adapts its internal payment processes, implementing measures to mitigate late payments in commercial transactions. These processes are implemented locally in compliance with legal and tax requirements. As a result, supplier contracts in 2024 include payment terms that are equal to, shorter than, or closely aligned with the standard payment terms in each country. However, different terms may be agreed upon by the parties. The average payment period to suppliers is defined as the time elapsed from the invoice date to the actual payment of the transaction. It should be noted that if a specific agreement with a supplier establishes payment terms that exceed the local standard payment term, payments to that supplier will be classified as late payment, even if they comply with the agreed terms between Cellnex and the supplier. Additionally, late payments resulting from administrative issues on the part of either Cellnex or the supplier are also reflected as late payments.