ESRS disclosure: ESRS S1 \ DR S1-6 \ Paragraph 50 d; ESRS S1

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  • Provide a detailed account of any significant changes to the policies adopted during the reporting year, particularly in relation to the undertaking's own workforce. This should include any new expectations for foreign subsidiaries, additional approaches to due diligence and remedy, and any policies or commitments aimed at preventing or mitigating risks and negative impacts on the workforce due to efforts in reducing carbon emissions and transitioning to greener operations. Additionally, outline any opportunities created for the workforce, such as job creation and upskilling, and include explicit commitments to a 'just transition.'
  • Question Id: S1-1_02

    In general, the policies updated during 2024 have been aligned with CSRD/ESRS, including it in the reference framework. Updated policies are communicated to all employees via the intranet and shared to all stakeholders through the IAR and the corporate website. The Sustainability Policy has been revised with updates to its basic principles, which now emphasise People First, a sustainable value chain, innovation, social value, integrity, and transparency. The action lines have also been adjusted to ensure they do not overlap with the basic principles. Additionally, a new section on Communication and Transparency has been introduced. The review of the Health & Safety Policy has been completed with key stakeholders, and its approval is planned for 2025. The new version essentially includes the changes listed below: The Reference Framework is updated in line with the new CSRD/ESRS and CSDDD standards as well as the other group policies on which this policy relies and should be interpreted together. The material aspects identified in the Double Materiality Assessment, along with the response to the IROs, have been incorporated into the policy. These aspects include Health & Safety within the value chain and Human Rights in the supply chain, specifically covering: Continuous improvement. Planning, evaluation and control. Risk Management. Responsibility of the Team and third parties. Communication and training. Information Management. The wording of the basic principles is reinforced to improve Cellnex’s positioning in relation to Health & Safety through the whole value chain in the ISO45001 standard, in the aspects related to: Consultation and participation Compliance Continuous improvement. The wording is strengthened to ensure compliance with all the requirements requested in the DJSI questionnaire. Within Governance and Accountability and Monitoring and Control, interactions with ARMC, EXCOM and integrations in the Sustainability strategy are detailed. Group People is assigned the task of drafting the strategy, instead of Management System. The EDI Policy has been updated, introducing key modifications as outlined below: Stronger Board oversight: the 2024 policy emphasises the Board’s responsibility for setting the EDI strategy, not just approving it. This signifies a greater level of ownership and commitment from the highest level of leadership. Policy Scope: the new version clarifies that the policy aims to materialise and consolidate the concept of diversity within the framework of Cellnex and communicate it to stakeholders. While the old version aims to provide guidelines. Zero tolerance policy Explicitly Stated: the 2024 policy adds a clear “zero-tolerance policy” for discrimination, bullying, and harassment, reinforcing its commitment to a respectful and inclusive workplace. It also includes a reference to the Whistleblowing Channel for reporting such incidents, providing a mechanism for accountability. Basic principles: the definitions of equity, diversity, and inclusion are more concisely presented in the new version. The older version discusses these concepts in the “Basic Principles” section, whereas the newer version integrates them into the introduction of the “Axes, Commitments and Strategic Lines” section. Emphasis on Social Responsibility: the new version strengthens the language around the company’s commitment to EDI as part of its social responsibility. Overall: the changes suggest a shift from a policy focused on high-level principles and commitments to a more action-oriented strategy with specific lines of action, measurable targets, and clearer accountability.

    Report Date: 4Q2024
  • Provide a detailed account of your organization's human rights policy commitments as they pertain to your own workforce. This should include an explanation of the processes and mechanisms in place to ensure adherence to the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. Emphasize the aspects that are materially significant and outline your general approach to these commitments.
  • Question Id: S1-1_03

    Cellnex is deeply committed to upholding human rights across all operations. The company’s Human Rights Policy is designed to ensure that all employees are treated with dignity and respect, and that their fundamental rights are protected. The Human Rights Policy applies to all of Cellnex's global operations. It covers all activities within the company’s value chain - both upstream and downstream- across diverse geographies. The policy is designed to safeguard the human rights of all stakeholders, including employees, contractors, and local communities impacted by the company’s operations. Cellnex commits to respecting the UN Guiding Principles on Business and Human Rights and the UN Global Compact through the implementation of its Human Rights Policy. These frameworks guide the company in aligning its practices with international human rights standards and expectations. The Human Rights Policy is published on the Cellnex website, making it accessible to all employees and external stakeholders. Cellnex ensures effective communication through both internal and external channels, engaging stakeholders and promoting awareness and understanding of the policy. Human Rights Due Diligence: as part of the company’s commitment to embrace, support, and respect human rights within its sphere of influence, Cellnex integrates core values in the areas of human rights, labour standards, environment, and anti-corruption into its operations. This is documented in the company’s Human Rights Policy. Cellnex voluntarily conducts an annual Human Rights Due Diligence exercise, which helps the organisation proactively identify and address any potential human rights issues. Integration with other policies: the Human Rights Policy is aligned with and complementary to other internal policies and regulations at Cellnex, such as the Environmental, Social and Governance (ESG) Policy, the Equity, Diversity and Inclusion (EDI) Policy, the Supplier Code of Conduct, the Code of Ethics, the Policy for the Whistleblowing Channel, the Anti-Bribery, Gifts and Hospitality Policy, and the Corruption Prevention Procedure. This holistic approach ensures that human rights considerations are embedded in all aspects of business operations. Such integration not only demonstrates Cellnex’s commitment to ethical business practices but also cultivates a culture of accountability and transparency—key elements in navigating the complex landscape of human rights considerations. Risk assessment and management: to have a more holistic understanding of the company’s adverse impacts, Cellnex assesses human rights risks based on its business relationships along its value chain and how the company relates to its stakeholders. This proactive approach allows Cellnex to identify and mitigate potential risks effectively.

    Report Date: 4Q2024
  • Provide a detailed description of your company's human rights policy commitments relevant to your own workforce. Include information on the processes and mechanisms in place to ensure compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. Focus on material matters and outline your general approach to respecting the human rights, including labor rights, of individuals within your workforce.
  • Question Id: S1-1_04

    Cellnex is deeply committed to upholding human rights across all operations. The company’s Human Rights Policy is designed to ensure that all employees are treated with dignity and respect, and that their fundamental rights are protected. The Human Rights Policy applies to all of Cellnex's global operations. It covers all activities within the company’s value chain - both upstream and downstream- across diverse geographies. The policy is designed to safeguard the human rights of all stakeholders, including employees, contractors, and local communities impacted by the company’s operations. Cellnex commits to respecting the UN Guiding Principles on Business and Human Rights and the UN Global Compact through the implementation of its Human Rights Policy. These frameworks guide the company in aligning its practices with international human rights standards and expectations. The Human Rights Policy is published on the Cellnex website, making it accessible to all employees and external stakeholders. Cellnex ensures effective communication through both internal and external channels, engaging stakeholders and promoting awareness and understanding of the policy. Human Rights Due Diligence: as part of the company’s commitment to embrace, support, and respect human rights within its sphere of influence, Cellnex integrates core values in the areas of human rights, labour standards, environment, and anti-corruption into its operations. This is documented in the company’s Human Rights Policy. Cellnex voluntarily conducts an annual Human Rights Due Diligence exercise, which helps the organisation proactively identify and address any potential human rights issues. Integration with other policies: the Human Rights Policy is aligned with and complementary to other internal policies and regulations at Cellnex, such as the Environmental, Social and Governance (ESG) Policy, the Equity, Diversity and Inclusion (EDI) Policy, the Supplier Code of Conduct, the Code of Ethics, the Policy for the Whistleblowing Channel, the Anti-Bribery, Gifts and Hospitality Policy, and the Corruption Prevention Procedure. This holistic approach ensures that human rights considerations are embedded in all aspects of business operations. Such integration not only demonstrates Cellnex’s commitment to ethical business practices but also cultivates a culture of accountability and transparency—key elements in navigating the complex landscape of human rights considerations. Risk assessment and management: to have a more holistic understanding of the company’s adverse impacts, Cellnex assesses human rights risks based on its business relationships along its value chain and how the company relates to its stakeholders. This proactive approach allows Cellnex to identify and mitigate potential risks effectively.

    Report Date: 4Q2024
  • Provide a detailed description of your organization's human rights policy commitments that pertain to your own workforce. Include an explanation of the processes and mechanisms in place to ensure compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. Emphasize the material aspects and your general approach to engaging with individuals within your workforce.
  • Question Id: S1-1_05

    Cellnex is deeply committed to upholding human rights across all operations. The company’s Human Rights Policy is designed to ensure that all employees are treated with dignity and respect, and that their fundamental rights are protected. The Human Rights Policy applies to all of Cellnex's global operations. It covers all activities within the company’s value chain - both upstream and downstream- across diverse geographies. The policy is designed to safeguard the human rights of all stakeholders, including employees, contractors, and local communities impacted by the company’s operations. Cellnex commits to respecting the UN Guiding Principles on Business and Human Rights and the UN Global Compact through the implementation of its Human Rights Policy. These frameworks guide the company in aligning its practices with international human rights standards and expectations. The Human Rights Policy is published on the Cellnex website, making it accessible to all employees and external stakeholders. Cellnex ensures effective communication through both internal and external channels, engaging stakeholders and promoting awareness and understanding of the policy. Human Rights Due Diligence: as part of the company’s commitment to embrace, support, and respect human rights within its sphere of influence, Cellnex integrates core values in the areas of human rights, labour standards, environment, and anti-corruption into its operations. This is documented in the company’s Human Rights Policy. Cellnex voluntarily conducts an annual Human Rights Due Diligence exercise, which helps the organisation proactively identify and address any potential human rights issues. Integration with other policies: the Human Rights Policy is aligned with and complementary to other internal policies and regulations at Cellnex, such as the Environmental, Social and Governance (ESG) Policy, the Equity, Diversity and Inclusion (EDI) Policy, the Supplier Code of Conduct, the Code of Ethics, the Policy for the Whistleblowing Channel, the Anti-Bribery, Gifts and Hospitality Policy, and the Corruption Prevention Procedure. This holistic approach ensures that human rights considerations are embedded in all aspects of business operations. Such integration not only demonstrates Cellnex’s commitment to ethical business practices but also cultivates a culture of accountability and transparency—key elements in navigating the complex landscape of human rights considerations. Risk assessment and management: to have a more holistic understanding of the company’s adverse impacts, Cellnex assesses human rights risks based on its business relationships along its value chain and how the company relates to its stakeholders. This proactive approach allows Cellnex to identify and mitigate potential risks effectively.

    Report Date: 4Q2024
  • Provide a detailed description of your company's human rights policy commitments relevant to your own workforce. Include an explanation of the processes and mechanisms in place to ensure compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. Focus specifically on material matters and outline your general approach to implementing measures that provide and/or enable remedy for human rights impacts.
  • Question Id: S1-1_06

    Cellnex is deeply committed to upholding human rights across all operations. The company’s Human Rights Policy is designed to ensure that all employees are treated with dignity and respect, and that their fundamental rights are protected. The Human Rights Policy applies to all of Cellnex's global operations. It covers all activities within the company’s value chain - both upstream and downstream- across diverse geographies. The policy is designed to safeguard the human rights of all stakeholders, including employees, contractors, and local communities impacted by the company’s operations. Cellnex commits to respecting the UN Guiding Principles on Business and Human Rights and the UN Global Compact through the implementation of its Human Rights Policy. These frameworks guide the company in aligning its practices with international human rights standards and expectations. The Human Rights Policy is published on the Cellnex website, making it accessible to all employees and external stakeholders. Cellnex ensures effective communication through both internal and external channels, engaging stakeholders and promoting awareness and understanding of the policy. Human Rights Due Diligence: as part of the company’s commitment to embrace, support, and respect human rights within its sphere of influence, Cellnex integrates core values in the areas of human rights, labour standards, environment, and anti-corruption into its operations. This is documented in the company’s Human Rights Policy. Cellnex voluntarily conducts an annual Human Rights Due Diligence exercise, which helps the organisation proactively identify and address any potential human rights issues. Integration with other policies: the Human Rights Policy is aligned with and complementary to other internal policies and regulations at Cellnex, such as the Environmental, Social and Governance (ESG) Policy, the Equity, Diversity and Inclusion (EDI) Policy, the Supplier Code of Conduct, the Code of Ethics, the Policy for the Whistleblowing Channel, the Anti-Bribery, Gifts and Hospitality Policy, and the Corruption Prevention Procedure. This holistic approach ensures that human rights considerations are embedded in all aspects of business operations. Such integration not only demonstrates Cellnex’s commitment to ethical business practices but also cultivates a culture of accountability and transparency—key elements in navigating the complex landscape of human rights considerations. Risk assessment and management: to have a more holistic understanding of the company’s adverse impacts, Cellnex assesses human rights risks based on its business relationships along its value chain and how the company relates to its stakeholders. This proactive approach allows Cellnex to identify and mitigate potential risks effectively.

    Report Date: 4Q2024
  • Disclose whether and how your company's policies concerning its own workforce align with relevant internationally recognized instruments, including the UN Guiding Principles on Business and Human Rights.
  • Question Id: S1-1_07

    Cellnex operates in alignment with these international reference standards, which serve as the framework for conducting the Human Rights Due Diligence process. This exercise aims to identify the most critical and prioritised actual and potential adverse impacts across the Cellnex value chain. Cellnex commits to regularly sharing its progress in adhering to human rights principles with internal and external right holders, thereby prioritising transparency and accountability. Cellnex voluntarily conducts an annual Human Rights Due Diligence exercise in accordance with the regulatory frameworks established by the OECD and the UN Guiding Principles on Business and Human Rights. The objective of this assessment is to identify the most critical and high-priority actual and potential adverse impacts across Cellnex’s entire value chain. In 2024 the assessment was aligned with the Corporate Sustainability Reporting Directive (CSRD) / ESRS requirements. This exercise provided a holistic view of the organisation’s operations, highlighting overlaps and gaps in human rights considerations within the broader context of sustainability. By adopting this integrated approach, Cellnex can be more effective at identifying and mitigating risks, ensuring that human rights considerations are adequately addressed within the broader framework of ESG risks. In this context, oversight of the Human Rights Due Diligence process falls under the purview of the Risk Management department, working in tandem with the ESG department. Together, they oversee the involvement of various company departments and are tasked with advocating, assessing, and reporting on the implementation of the Human Rights Policy at both local and global levels. The report related to the Human Rights Due Diligence and Assessment Process is available on the corporate website.

    Report Date: 4Q2024
  • Does the undertaking have a workplace accident prevention policy or management system in place?
  • Question Id: S1-1_09

    Cellnex has fostered a Safety Culture grounded in its core values across all the countries where it operates. Occupational Health and Safety (OHS) aspects are integrated into the strategy and guiding principles outlined in the organisation’s global Health and Safety (H&S) policy. It is worth noting that Cellnex is currently updating this policy, aligning it with the new CSRD regulation, which is set to be approved in 2025. The Health and Safety Policy covers all Cellnex Group companies, focusing on sensitive workers across the entire value chain, including upstream and downstream activities. It applies to all operational geographies and aims to protect employees, contractors, and other stakeholders from health and safety risks. The Health and Safety Policy is primarily managed by the Health and Safety Department, under the oversight of the Board of Directors. This ensures that the policy is effectively implemented at both operational and strategic levels, with senior leadership holding ultimate accountability for its success.

    Report Date: 4Q2024