Cellnex places significant emphasis on fostering a strong corporate culture that aligns with its purpose, values, and strategic objectives. This is achieved through a combination of structured engagement, clear communication, and incentive programmes designed to encourage alignment with the company’s values and goals. To ensure that the management and supervisory bodies are actively engaged with corporate culture, Cellnex conducts an annual Employee Engagement Pulse survey across the entire group. This survey assesses engagement levels, alignment with purposes and values, and gathers open feedback on areas for improvement. The results are presented to the Executive Committee (ExCom), which defines specific action plans to address key findings. These plans are integrated into the objectives of each ExCom member and included in their Management by Objectives (MBO) scheme, thus ensuring accountability and continuous improvement. The promotion and communication of corporate culture are anchored in Cellnex’s core values: Commitment, Entrepreneurship, Inclusion, Integrity, and Sustainability. These values form the foundation of initiatives aimed at fostering a unified “One Cellnex” team. Through purpose-driven leadership, the company promotes ethical behaviour, a growth-focused mindset, diversity and inclusion, and sustainability. This approach not only enhances employee engagement, but also drives innovation and ensures long-term organisational success. Key messages about corporate culture and strategic priorities are communicated directly to employees through Group Town Hall meetings, where the leadership provides updates on business performance and strategy, while offering employees the opportunity to ask questions. These meetings are essential for maintaining transparency and alignment across all levels of the organisation. To encourage and reinforce the desired corporate culture, Cellnex implements various recognition programmes. These include the annual Love Awards, which celebrate outstanding contributions, and the Love Broadcasters internal communications campaign, which amplifies messages of appreciation and engagement.

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 company aims to forge business relationships that are based on honesty and transparency, rejecting any conduct that aims to gain preferential treatment in both the public and private sectors. To reinforce Cellnex’s commitment to anti-bribery and anti-corruption, several policies were updated to implement the company’s Anti-Bribery Management System, to comply with ISO 37001 and strengthen the ethics framework.

The company aims to forge business relationships that are based on honesty and transparency, rejecting any conduct that aims to gain preferential treatment in both the public and private sectors. To reinforce Cellnex’s commitment to anti-bribery and anti-corruption, several policies were updated to implement the company’s Anti-Bribery Management System, to comply with ISO 37001 and strengthen the ethics framework.

Cellnex adopts a zero-tolerance policy for retaliation. The company safeguards whistleblowers by ensuring that no individual who reports concerns in good faith will face retaliation. If any whistleblower perceives that they have been subjected to retaliation, they are encouraged to report this immediately, and the company will take appropriate action to investigate and address the issue. All whistleblowers are guaranteed confidentiality and protection in line with applicable laws, including the EU Whistleblower Directive (2019/1937).

Cellnex adopts a zero-tolerance policy for retaliation. The company safeguards whistleblowers by ensuring that no individual who reports concerns in good faith will face retaliation. If any whistleblower perceives that they have been subjected to retaliation, they are encouraged to report this immediately, and the company will take appropriate action to investigate and address the issue. All whistleblowers are guaranteed confidentiality and protection in line with applicable laws, including the EU Whistleblower Directive (2019/1937).

Cellnex adopts a zero-tolerance policy for retaliation. The company safeguards whistleblowers by ensuring that no individual who reports concerns in good faith will face retaliation. If any whistleblower perceives that they have been subjected to retaliation, they are encouraged to report this immediately, and the company will take appropriate action to investigate and address the issue. All whistleblowers are guaranteed confidentiality and protection in line with applicable laws, including the EU Whistleblower Directive (2019/1937).

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 is committed to fostering a culture of integrity and ethical business conduct through a comprehensive training policy. For this reason, it has implemented mandatory training programmes for all employees, which cover key topics such as ethical behaviour, compliance standards and legal obligations. Training is delivered through a combination of in-person sessions, e-learning modules, and periodic refresher courses to ensure ongoing awareness and alignment with Cellnex’s policies. To assess the effectiveness of these programmes, the company regularly conducts tests, gathers feedback through surveys, and performs compliance reviews.

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.