Cellnex

The role of the administrative, management and supervisory bodies

Reference: pages 59-62.

The Board of Directors has 10 members. A competence-matrix heatmap shows board-level sustainability capability: "Sustainability/Climate Change/Environment" is rated 20% solid, 80% strong (no director rated merely exposed) (page 60).

Three Board committees divide ESG oversight: the Nominations, Remunerations and Sustainability Committee (NRSC, 4 members, 12 meetings in 2025, 93.75% attendance) "regularly reports to the Board of Directors on sustainability information that the company must disclose"; the Audit and Risk Management Committee (ARMC, 4 members, 9 meetings, 87.5% attendance) oversees the Internal Control System for Sustainability Reporting; and the Capital Allocation Committee (5 members, 10 meetings, 98% attendance) (pages 60-61).

"Members of the Executive Committee are responsible for proposing objectives linked to material IROs and monitoring their progress" (GOV-1/22(d), page 61).

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Reference: pages 63-64.

"The Global Sustainability Director reports regularly to the Nominations, Remunerations and Sustainability Committee (NRSC)... In 2025, ESG topics were discussed in 58% of NRSC meetings (7/12) and 22% of ARMC meetings (2/9)" (GOV-2/24, page 63).

The Executive Committee "oversaw and approved the development of the Sustainability Master Plan 2030, prior to its submission to the NRSC and subsequent Board approval on 30 September 2025." A table sets out topic-by-topic oversight split between the NRSC, ARMC and Executive Committee, keyed to specific IRO numbers (e.g. NRSC: "Climate Change (IROs 1,2,3) and Energy Mgmt. (IROs 4,5,6)"; ARMC: "Business Continuity (IROs 19, 20)") (page 63).

Integration of sustainability-related performance in incentive schemes

Reference: page 63.

"In 2025, long-term incentive plans (LTIP) have included financial and sustainability-linked metrics" across four overlapping vesting periods (2023-2025, 2024-2026, 2025-2027, 2026-2028) (GOV-3/29, page 63). Metrics cited in the LTIP table include a Scope 3.1+3.2 absolute-emissions-reduction target versus FY20, a 100% green-energy metric, and a target for women among directors and Senior Management.

Separately, "Cellnex integrates climate-related targets into the Long-Term Incentive Plan" (E1-1/16(c), page 88). A footnote states "the remuneration of BoD members doesn't include metrics linked to ESG priorities" (page 64), so the sustainability link applies to management incentive plans, not director pay.

Statement on due diligence

Reference: page 64.

"Cellnex integrates sustainability due diligence into its governance, strategy and operations to systematically identify, assess and manage actual and potential impacts... aligned with international frameworks such as the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises" (GOV-4/30, page 64).

A table maps the four due-diligence core elements to specific report sections: embedding in governance/strategy to section 2.2/2.3; stakeholder engagement to section 2.3.2 (SBM-2); identifying and assessing impacts to section 2.4 (IRO-1, SBM-3); and tracking effectiveness to section 2.5 (MDR-M, MDR-T), citing the Cellnex Foundation's Bridge Programme as a concrete stakeholder-input example (page 64).

Risk management and internal controls over sustainability reporting

Reference: pages 64-66.

"In 2025, Cellnex has implemented an Internal Control System for Sustainability Reporting (ICSR) in accordance with the international internal control standards established by COSO... In this first exercise critical data points have been included in the control system" (GOV-5/34, page 65).

The ICSR is built through a five-step process (definition/scope, reporting-process analysis, risk/control identification, control-campaign launch, assessment of controls) covering KPIs such as carbon-footprint methodology, EU Taxonomy reporting, compensation pay gap and whistleblowing incidents, scored by "five categories (integrity and accuracy, complexity and subjectivity, governance and coordination, strategic relevance, regulatory risk)" (page 65). The Internal Audit Department evaluates its operational effectiveness annually (page 66).

Strategy, business model and value chain

Reference: pages 66-69.

"Cellnex's neutral, shared infrastructure business model embeds sustainability into its strategy... With a portfolio of 113,801 sites (112,105 in 2024), Cellnex conducts its operations across Europe" across towers, fiber connectivity, DAS/Small Cells/RAN-as-a-Service and audiovisual broadcasting (SBM-1/40, page 67), employing 2,511 people across 10 countries (page 67).

In 2025 the Board approved the Sustainability Master Plan 2030, succeeding the 2021-2025 ESG Master Plan, organised around four pillars - Resilient infrastructures, Climate action, Customer focus & Business conduct, People first - each with quantified 2030 KPIs, e.g. "2050 Net-Zero emissions" and "100% renewable electricity from FY25" (pages 68-69).

Interests and views of stakeholders

Reference: pages 69-74.

Cellnex groups stakeholders into eight categories (customers, employees, investors/shareholders, landlords, suppliers, public administration/regulators, media, communities/NGOs), each mapped to dedicated engagement tools, e.g. for employees: "Intranet... Pulse Survey... Nominations, Remunerations and Sustainability Committee (NRSC)" (page 72).

"Cellnex is member of the UN Global Compact (UNGC) since 2015" and in 2025 "led the ESG Working Group" of the European Wireless Infrastructure Association (EWIA), coordinating "carbon-footprint accounting, double materiality and CSRD reporting" across European TowerCos, and signed to join the World Economic Forum (page 73).

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: pages 75-79.

The double materiality assessment, last fully updated in 2024 and re-validated by the NRSC in October 2025, identified "11 material environmental, social, and governance (ESG) topics" from "the top 10 impacts and the top 10 risks and opportunities" (SBM-3/46, IRO-2/56, page 78) - tabulated as 20 individually typed IROs across E1, E4, S1, S2, G1 and two entity-specific topics (pages 75-76). "At the end of 2025, a new double materiality assessment was started, to be completed in 2026" (page 75).

Material topics are: Climate change, Energy management, Biodiversity, Gender and cultural diversity, Talent attraction and retention, Health and safety in the value chain, Human rights in the supply chain, Ethics and compliance, Responsible supply chain, plus entity-specific Operational efficiency/business continuity and Cybersecurity (page 79).

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: pages 77-78.

A four-stage process: "1) understanding the context, 2) identification of IROs, 3) IROs evaluation... 4) Results and validation." Stage 2 drew on "risk exercises aligned with TCFD, TNFD, Human Rights due diligence and the corporate ERM risk assessments," plus the Pulse Survey and Customer Engagement Survey, producing "a list of 144 IROs," streamlined to "a short list of 60 IROs for evaluation" (page 77).

Impact materiality = likelihood x severity; financial materiality = likelihood x magnitude, with severity prioritised over likelihood for human-rights impacts "consistent with UNGPs and ESRS requirements" (page 78). The short list was narrowed to the 20 IROs underlying the 11 material topics.

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: pages 219-224 (section 7.3 Index of regulation CSRD/ESRS).

Cellnex publishes a dedicated ESRS content index mapping each disclosure requirement code to the Integrated Annual Report section addressing it, covering BP-1/BP-2, the full ESRS 2 set, E1 (climate change), E4 (biodiversity), S1 (own workforce), S2 (workers in the value chain) and G1 (business conduct), plus two entity-specific topics. The index explicitly marks G1-5 (political influence and lobbying) "No material" rather than citing a page (page 222), and the report states that the double materiality results under IRO-2/56 and IRO-2/59 "determine the ESRS to be applied in the Sustainability Report" (page 78).

Transition plan for climate change mitigation

Reference: pages 88-90.

"In 2025, Cellnex renewed the SBT ambition adopted in 2021... The new Climate Transition Plan reaffirms Cellnex net-zero 2050 ambition" (E1-1/14, page 88), validated by SBTi in December 2025: near-term "(70)% absolute Scope 1 and 2 (market-based) GHG emissions by 2030 from a 2020 base year," "100% renewable electricity sourcing by 2025," "82% of suppliers and customers emissions with science-based targets by 2030"; long-term "(90)% absolute Scope 1 and 2... and (90)% absolute Scope 3 emissions by 2050" (page 88). Cellnex "achieved carbon neutrality for Scopes 1 and 2 vs 2020, while withdrawing its previous commitment to neutralise Scopes 1, 2 and 3 by 2035" (page 88).

Three decarbonisation levers are named - smart energy, value chain, circular economy (page 89). Locked-in emissions are addressed qualitatively: Scope 2 is "fully addressed" via 100% renewable electricity; embodied Scope 3 emissions "are not material for Cellnex" (E1-1/16(d), page 89). "The financial resources allocated to the actions... do not represent a material amount in isolation" except an EU-Taxonomy-aligned 2.3M€ energy-efficiency investment (page 97). The Plan was presented to the NRSC, which reports to the Board (E1-1/16(i), page 89).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 SBM-3 and IRO-1, where this content is disclosed in the FY2025 report (pages 90-93). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risks are classified as transition (carbon/renewable pricing, regulation, value-chain dependency) or physical (acute: wildfires, storms; chronic: rising temperatures, sea-level rise) (page 89). Methodology: site-level vulnerability uses geo-located data, IPCC-aligned physical scenarios (SSP2-RCP4.5 "realistic," +2.5-3C by 2100; SSP5-RCP8.5 "worst case," +4.5-6C) across short (2020-2040), medium (2040-2070) and long (2070-2100) horizons, covering "100% of sites analysed" with 15-25% at high/critical risk depending on scenario and country (pages 92-93).

Transition scenarios use NGFS (Net-Zero 2050, Delayed transition, Current policies), naming projected warming (1.4C/1.7C/3C) and policy-reaction assumptions (page 91). "Cellnex performed its most recent climate vulnerability assessment in 2024," using external NGFS/IPCC sources (SBM-3/19(b), page 90); the report does not state the 2025 assessment was refreshed.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 90-92). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"Cellnex has assessed the resilience of its strategy and business model to climate-related risks and opportunities in line with the TCFD recommendations... The risk assessment covers the full Cellnex value chain, including telecom infrastructure, data centers, energy pass-through, supply chain dependencies, and customer-related exposures" (SBM-3/19(a), page 90).

Results: "the scenario analysis confirms that Cellnex's business model remains resilient under all analysed scenarios and that the anticipated financial effects remain low. Physical risks become more material under high-warming scenarios... manageable through planned adaptation measures" while transition risks "are mitigated through Cellnex's decarbonisation roadmap" (SBM-3/19(c), page 92), cross-referencing E1-9 (financial effects, page 104) and E1-3 (mitigation actions, page 95). No explicit statement of assessment uncertainty or of capacity to redeploy financial resources was found in the report; adaptation planning under the Sustainability Master Plan 2026-2030 is noted (page 93).

Policies related to climate change mitigation and adaptation

Reference: pages 94-95.

"Cellnex addresses climate mitigation and adaptation through its Group Environment and Climate Change Policy... applied across operations and the value chain," supported by the Sustainability Policy, Energy Policy, Global Procurement Policy, Global Risk Management Policy and Code of Ethics (E1-2/22, page 94).

The Environment and Climate Change Policy commits Cellnex to: climate change mitigation ("Achieve Net-Zero through a climate transition plan with short-, medium- and long-term science-based emission-reduction targets"), climate change adaptation ("Assess the vulnerability of sites to climate risk and strengthen its resilience"), circular economy and environmental stewardship via a Group-wide ISO 14001 system (page 94). The Energy Policy separately commits to "100% renewable electricity by 2025" and an ISO 50001 energy-management system, administered by the Energy Department (page 95).

Actions and resources in relation to climate change policies

Reference: pages 95-98.

The Energy Transition Plan runs on four pillars. Smart energy: "In 2025, 100% of the overall electricity consumption was certified as renewable," with PPAs securing "400 GWh/year of green electricity until 2035" (28% of 2025 consumption) (page 96). Energy efficiency: ISO 50001 "now covers four countries - 81% of electricity use"; Tower Energy Efficiency Index (TEEI) "is 1.14" in 2025 (page 96); efficiency levers delivered "1.6 M€ and 0.5 GWh of energy savings" plus 5.9 GWh/yr of solar self-generation across 700+ sites (page 97).

Circular economy: a 2025 tower-standardisation project harmonises steel-component design to raise recycled-steel content (page 97). Value chain: the CDP Supply Chain programme engaged "242" suppliers (84% response rate) and the Supplier Engagement Programme calculated carbon footprints for "64" suppliers in 2025, contributing to a "(21)% reduction in procurement-related emissions (Scopes 3.1 and 3.2)" (page 98).

Targets related to climate change mitigation and adaptation

Reference: pages 98-99.

SBTi-validated targets from a 2020 base year (E1-4/30, page 99): near-term "Reduce 70% absolute Scope 1 and 2 GHG emissions by 2030 vs 2020," "100% renewable electricity from 2025 through 2030," "82% of suppliers and customers emissions with SBT by 2030"; long-term "Reduce 90% absolute Scope 1 and 2 GHG emissions and absolute Scope 3 by 2050 vs 2020." Cellnex also targets phasing out fossil-fuel fixed generators at TIS sites by 2035 (page 99).

Progress against the milestones table: Scope 1+2 market-based emissions fell from 437,216 tCO2e (2020 base) to 20,541 (2024) to 5,165 tCO2e (2025), a (99)% reduction versus base year against a 2030 target of (70)%; renewable electricity sourcing reached 100% in 2025 against the 2025/2030 target of 100% (page 99).

Energy consumption and mix

Reference: pages 99-100.

Total energy consumption was 1,421,442 MWh in 2025 (1,431,745 in 2024; 1,160,230 in the 2020 base year) (E1-5/37, page 100). Renewable-source consumption reached 1,408,946 MWh, essentially matching total consumption once fossil sources (diesel, gasoline, natural gas) fell to residual levels, since grid electricity purchases were fully renewable-certified and self-generated electricity added 5,921 MWh.

By country, "Italy represents half of Cellnex's total energy use, as it is the market with the largest portfolio of towers for which Cellnex directly manages the energy supply," while "Portugal's energy consumption increased notably due to the expansion of site portfolio under direct energy management." Non-electrical energy is "less than 1% of the Group's total energy consumption" (page 100).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 100-102.

Methodology: ISO 14064-1:2018, "100% of Group revenues and reporting perimeter," verified "by TUV Rheinland with limited assurance" (E1-6/44, page 101). Gross Scope 1: 4,908 tCO2e (2025) vs 5,137 (2024). Gross market-based Scope 2: 28 tCO2e (2025), down (100)% from 15,633 (2024), reflecting the shift to 100% renewable electricity. Total gross Scope 3: 603,073 tCO2e (2025) vs 803,745 (2024), a (25)% year-on-year fall, led by Scope 3.13 downstream leased assets ((54)%) and Scope 3.1/3.2 purchased goods/capital goods ((18)%/(21)%).

Total GHG emissions (market-based): 608,238 tCO2e in 2025 versus 824,286 in 2024 ((26)%) and 1,678,886 in the 2020 base year ((64)%) (page 101). 2020 and 2024 inventories were recalculated to exclude Austria, Ireland and MBA Datacenters (page 101).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: pages 102-103.

"Cellnex's 2025 offsetting strategy focuses on high-integrity, government-endorsed carbon-removal projects. The Group does not develop its own carbon storage or removal projects... and participates exclusively in carbon-removal initiatives outside its value chain" (E1-7/56, page 102). "In 2025, Cellnex offset 5,142 tCO2e, representing 1% of the carbon footprint," 79% VCS/Gold Standard certified and 18% located within the EU (page 102).

Projects are named by country: blue-carbon restoration in Venezia (Italy), reforestation in Preuilly-sur-Claise and Le Bois du Grand Pont (France), native-forest restoration near Loch Ness (UK, 100,000 trees), and reforestation in Campo Lameiro (Spain, c.20 ha) (page 103). "Cellnex will keep neutralising its residual Scope 1 and 2 until 2030. From 2030 onwards, Scope 3 will be progressively offset until 2050" (page 103).

Internal carbon pricing

Reference: page 104.

"In 2025 Cellnex has established an Internal Carbon Price (ICP) using a shadow price approach... modelled on the NGFS climate scenarios (Current Policies, Delayed Transition and Net-Zero 2050) using the REMIND-MAgPIE model as the main reference, complemented by a Country Alignment Index (CAI)" and adjusted to EU-ETS signals (E1-8/62, page 104).

"In 2025, aligned with the NGFS Net-Zero scenario, the cost range is from 133 to 215 euro/tCO2e, depending on the country where the ICP is applied." It currently covers new-site construction (Scope 3.2), "represent[ing] c. 40% of Scope 3.2 emissions," and from 2026 extends to internal tower-construction projects in Spain, France, Sweden, Poland, Italy and Denmark (page 104).

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Reference: pages 104-105.

Five named risks span market, policy/legal, reputational, acute and chronic categories - e.g. "CR1 Decarbonisation cost uncertainty (Scope 1 and 2)" (medium-term, OpEx impact) and "CR5... chronic risk impacting sites" (long-term, OpEx/CapEx impact from cooling needs and sea-level rise) (E1-9/66, page 104). Three opportunities are named, including "CO1 Energy strategy for sites" (OpEx reduction via efficiency and self-generation).

"Climate-related risks and opportunities have a financial impact below 1% of revenue. Therefore, they are classified as low under the company's Global Risk Management methodology" for every listed item (page 105). "In 2024, the methodology was adapted to CSRD requirements; in 2025, updated operational and financial data confirmed the low potential financial impacts identified last year" (E1-9/64, page 104).

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Reference: page 106.

"Cellnex evaluates nature-related risks, dependencies, and opportunities using the Taskforce on Nature-Related Financial Disclosures (TNFD) framework as an early adopter. In 2025, Cellnex reviewed its TNFD analysis and mapped new sites in protected areas" (E4-1/11, page 106). "While no scenario-based resilience analysis has been conducted to date, this will be undertaken as part of the next update of the nature strategy" (page 106).

"Percentage of sites in protected areas according to the IUCN": 100% of sites analysed, 8% located in protected areas (page 106). Cellnex "applies the mitigation hierarchy to prioritise actions in line with best practices across its operations and supply chain" and will update its biodiversity strategy and metrics under the 2026-2030 Sustainability Master Plan.

Policies related to biodiversity and ecosystems

Reference: pages 107-108.

"Cellnex's Environment and Climate Change Policy adopts an integrated approach to climate, biodiversity and natural capital, with a focus on land use, birdlife and landscapes. Aligned with TNFD, the Global Biodiversity Framework and the Nature Positive Initiative" (E4-2/20, page 108), using "the LEAP approach (Locate, Evaluate, Assess, Prepare)" and applying "a No Net Loss approach" to compensate residual impacts.

"The policy commits to due diligence in protected areas, compliance with environmental requirements, and the prevention of deforestation and net land conversion" (E4-2/24, page 108), prioritising decarbonisation, minimising land-use change, applying the mitigation hierarchy and preventing pollution (E4-2/23, page 107-108).

Actions and resources related to biodiversity and ecosystems

Reference: pages 108-109.

"Storks' empty nests are removed after the nesting season, if allowed by local regulations, to prevent tower damage and safety risks. Nest baskets are then installed to promote nesting in safe conditions. In Spain, 43 nest baskets have been installed in 2025" (E4-3/28, page 109). Peregrine-falcon nesting boxes are installed in Spain and the Netherlands (page 108).

Country-level actions include a Life Nature fund project (Spain) to compensate for stork-related biodiversity loss, a University of Manchester Innovation Lab collaboration (UK) to co-design telecom-site biodiversity solutions, a one-for-one tree-replacement policy in Sweden (1,000 trees planted, 1,000 more scheduled for 2026) and 350 trees replanted in Portugal (page 109). Carbon-offset nature restoration is cross-referenced to E1-7.

Targets related to biodiversity and ecosystems

Reference: page 109.

"Cellnex has adopted policies and objectives related to nature as part of its sustainability strategy to reduce impacts and risks. However, these commitments still need to be linked to measurable goals and specific targets in line with the planned roadmap for the nature-related aspects that apply to Cellnex" (E4-4/29, page 109).

This is a direct statement that Cellnex has not yet set quantified biodiversity targets, distinguishing it from the company's approach to climate (E1-4) and diversity (S1-5), where numeric targets exist. The report frames target-setting as planned future work tied to the 2026-2030 Sustainability Master Plan and a forthcoming sector-specific biodiversity metric (E4-5, page 109).

Impact metrics related to biodiversity and ecosystems change

Reference: pages 109-110.

Land use per ecosystem type, FY2025: total footprint 11.99 km2, of which 57% artificial surfaces, 26% homogeneous agricultural area, 6% forests and 0.3% wetlands (page 109). TNFD core metrics: total spatial footprint by business line - "Data centers: 0.002 km2; TIS: 11.80 km2; Broadcast: 0.20 km2" - and "Total land use change: 0.41 km2" (E4-5/35, page 110).

"Cellnex tracks the physical footprint of its infrastructure using TNFD core metrics on total land use and land use by ecosystem type, calculated through geographical information overlays on CORINE Land Cover" (page 110). "In 2026, Cellnex plans to explore its own biodiversity metric that could be extended to the telecommunications tower sector," and a dedicated birdlife-impact metric is planned for 2026 (page 110).

Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities

Reference: page 111.

Three physical/transition risks are quantified qualitatively: bird nesting on towers (policy/legal, short-term, OpEx from nest removal, impact "Low"), sites in protected natural areas (reputational, medium-term, CapEx/OpEx, impact "To be calculated"), and fire risk at rural sites (acute, short-term, OpEx/CapEx, "Low") (E4-6/42-45, page 111). Opportunities include nature-based resilience solutions and site rationalisation, both "To be calculated."

"The CSRD methodological update in 2024 and the 2025 data refresh confirm low potential financial impacts. Although progress was made in 2025 in quantifying the financial impacts of nature-related risks and opportunities, access to certain information remains challenging, and further work will continue throughout 2026" (page 111).

Policies related to own workforce

Reference: pages 125-130.

Five named policies with MDR-P elements: the Equity, Diversity, and Inclusion (EDI) Policy ("addresses risks of inequality in hiring and under-representation across five key diversity dimensions"), the Talent Management Model & Compensation policy, the Hiring Guide, the Human Rights Policy, and the Sensitive Risk Group Workers Policy (pages 126-127). The Human Rights Policy is "framed within internationally recognised instruments including... the eight core conventions of the ILO... UN Guiding Principles on Business and Human Rights" (S1-1/21, page 127).

The OHS Policy was restructured in 2025, "reduc[ing] core principles from eight to six," expanding scope to "all Group companies and the entire value chain," and adding NRSC governance oversight (page 127). "In 2025, 17 actions have been launched achieving a high compliance of 95%" (page 128).

Processes for engaging with own workforce and workers' representatives about impacts

Reference: pages 130-133.

Direct engagement mechanisms include the annual Employee Engagement Survey (Pulse Survey), quarterly consultations with legal representatives under Spanish law, town halls ("5 global town halls" in 2025), and executive sessions "Cellnexians Coffee" and "Meet Marco" (S1-2/27, pages 131-132).

Pulse Survey 2025 results: participation 85% (83% in 2024), Inclusion (EDI) 76%, Engagement 72%, Sustainability (Well-being) 76% (page 132). Country-specific mechanisms are tabulated, e.g. France's mandatory monthly Works Council (CSE) consultations and the UK's "Listening Circles" on wellbeing, development, pay and inclusion feeding a "Colleague Engagement Improvement Plan" (page 133).

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: pages 133-135.

"Cellnex's approach to remedy prioritizes prevention, early detection, and the effective management or remediation of any adverse impacts," including "harassment prevention and resolution," a "Quarterly People Health Index" tracking turnover, and union collaboration on redundancy transitions (S1-3/32(a), page 133-134).

The Whistleblowing Channel, "managed by an independent third party," and Human Resources Business Partners (HRBPs) are the primary reporting routes (S1-3/32(b), page 134). "Cellnex closely monitors how grievance channels are used and how effective they are. All reports are kept confidential, and corrective actions are taken when needed" (S1-3/32(e), page 135), with mandatory training ensuring awareness for all employees, including new hires.

Taking action on material impacts on own workforce

Reference: pages 135-140.

Cellnex ties actions directly to its material workforce IROs - gender and cultural diversity, and talent attraction and retention (S1-4/35, page 135) - through initiatives such as the EDI Policy, the "Female Empowerment Itinerary" internal community programme, mandatory "Unconscious Bias" training launched in 2025, and internal-mobility programmes.

Occupational health and safety actions are integrated as a cross-cutting mitigation: the OHS management system, health surveillance for sensitive-risk groups, and preventive-maintenance innovations (drones, digital twins) reduce exposure to high-risk work at height (pages 128-129). Financial and non-financial resources are drawn from the People Department and Health and Safety Department budgets, tracked through the Holistic Performance Management (HPM) framework.

Targets related to own workforce

Reference: pages 144-145.

FY2025 quantified targets versus outcomes (MDR-T/80, page 144): women in management positions, target 30%, achieved 32% in 2025 (down from 34% in 2024 but still above the target floor); hires of women, target 50%, achieved 42%; hires of young talent, target 30%, achieved 27%; international directors at Cellnex HQ, target 60%, achieved 38%; career advancement for women, target 40%, achieved 40%.

Additional social targets: Employee Engagement Survey response >=70%, achieved 72%; "ESS >=60% Favorable wellbeing scores in all BUs or improve by 5%," achieved 67%; inclusive-leadership Pulse Survey score target >=75%, achieved 76%; ESG annual training participation target from 2023 >=90%, achieved 94% (page 144).

Characteristics of the undertaking's employees

Reference: pages 146-148.

Total headcount 2,511 employees in 2025 (2,604 in 2024), consistent with the average headcount reported under Note 18(b) of the consolidated financial statements (S1-6/48, page 147). Gender split: 812 women (32%), 1,699 men (68%). By country, Spain has the largest workforce (1,050, 306 women/29%), followed by Poland (398) and France (322) (page 147).

"Vulnerable employee" categories are named: workers with disabilities, pregnant/breastfeeding women, temporary workers, and workers performing tasks at height, each receiving "targeted preventive measures" and workplace adjustments (S1-6/48, page 146). Contract-type and full-time/part-time breakdowns are also tabulated by country and gender (page 147-148).

Characteristics of non-employee workers in the undertaking's own workforce

Reference: pages 149-150.

"An external employee is not a formal employee of Cellnex but performs specific and occasional task or services related with Cellnex's activities within the framework of outsourcing relationships or temporary employment agreements with Temporary Employment Agencies (TEAs)" (S1-7/53, page 150).

"Given that the phasing-in period has been extended by one year, the number of non-employees is not yet reported, but as a measure of transparency, the type of non-employees is reported in qualitative terms in order to anticipate the communication of this data" (S1-7/55(c), page 150). Non-employees are described as "temporary agency workers, contractors, self-employed individuals, and subcontractors," excluding consultants and maintenance services (page 150).

Collective bargaining coverage and social dialogue

Reference: pages 153-155.

Group collective-bargaining coverage rose to 68% in 2025 from 64% in 2024 (S1-8/60(b), page 155). Country practices vary widely: Spain has two Cellnex-Group companies with their own CBAs plus a metal-industry-sector fallback CBA; Poland, the Netherlands, Switzerland and Denmark have no CBA and rely on national labour law and Works Councils instead; Sweden has near-universal CBA coverage except the CEO (page 154).

"There is no existence of an agreement with employees for representation by European Works Council (EWC), Societas Europaea (SE) Works Council, or Societas Cooperativa Europaea (SCE) Works Council on a company level" (S1-8/63(b), page 155).

Diversity metrics

Reference: page 151.

Employee headcount by gender and professional category, 2025 (S1-9/66, page 151): women are 7% of Senior Management (1 of 15), 27% of Directors (23 of 85), 34% of Managers (118 of 352), and 33% of Coordinators/Other professionals (670 of 2,059) - a clear seniority gradient, with 2024 comparatives of 13%, 23%, 35% and 32% respectively showing women's share of Senior Management and Directors roles rising year on year while Managers held broadly flat.

This directly informs the company's material talent-attraction/gender-diversity IRO and links to the S1-5 targets on women in management (30% target, 32% achieved in 2025) and career advancement for women (40% target, 40% achieved), tracked through the SuccessFactors-derived headcount database referenced at S1-6/50(c) (page 150).

Adequate wages

Reference: page 155.

"Cellnex ensures that all employees receive an adequate wage in line with or above relevant market benchmarks and living wage standards, as defined in the Group's Remuneration Policy" (S1-10/67, page 155), reviewed annually with consulting firm Willis Towers Watson.

Ratio of standard entry-level wage to local statutory minimum wage, 2025: Group average 1.51 (1.41 in 2024), ranging from 1.20 in Italy to 1.95 in Switzerland (S1-10/69, page 155), with France, UK, Poland and Denmark not applicable because those countries have no statutory interprofessional minimum wage. "Standard entry-level wage is defined as the lowest base including all fixed guaranteed pay for all non-apprentice/non-intern employees" (page 155).

Social protection

Reference: pages 156-157.

"Cellnex ensures that employees in all countries where it operates are covered by social-protection schemes that mitigate income loss linked to major life events... through either national social-security systems or... company-funded benefits" across sickness, unemployment, injury/disability, parental leave and retirement (S1-11/72, page 156). Country detail: e.g. France gives "100% salary for the first 45 days of sick leave," dropping to 90% until day 105; the Netherlands pays "100% of salary... during the first year of illness; reduction to 70% in the second year" (page 156).

"Countries with gaps in social protection" is disclosed explicitly: in the UK, only employees with 12+ weeks' tenure qualify for company sick pay or Maternity Pay, though statutory minimums still apply (S1-11/75, page 157).

Persons with disabilities

Reference: page 152.

"Employees with disabilities in own workforce" totalled 34 in 2025 (1% of headcount), up from 27 (1%) in 2024 (S1-12/79, page 152). By country, Italy has the highest share at 8% (18 of 232 employees), followed by France at 2% (8 of 322); most other countries report none. By gender, 17 women (2%) and 17 men (1%) were recorded with disabilities in 2025.

Methodology: the figure "includes individuals with a recognised disability of 33% or more, or those certified by Social Security as having a permanent total, absolute, or severe disability" (S1-12/80, page 152).

Training and skills development metrics

Reference: pages 152-153.

"The total hours of training in 2025 was 57,750.37 (65,245.21 in 2024)" (S1-13/81, page 152), spread across categories including "Safety in the workplace" (10,051 hours), "Cybersecurity" (4,806 hours), "Human rights" (1,697 hours) and "Anti-corruption" (2,026 hours) (page 153). Average training hours per employee: women 738 (2025) vs 1,003.65 (2024); men 881 vs 1,091 (page 153).

Performance-review participation reached 100% of the workforce in 2025 (98% in 2024) (S1-13/83(a), page 152). The flagship "Leaders of Tomorrow" programme applies a "70-20-10 learning model" combining culture, business knowledge and networking for high-potential employees (page 152).

Health and safety metrics

Reference: pages 157-158.

"In 2025, 100% of Cellnex's own workforce was covered by the Occupational Health and Safety Management System... audited and certified by an external party in all countries where ISO 45001 certification is implemented. Sweden and Denmark are the only exceptions" (S1-14/86-88, page 157).

2025 own-workforce figures: 7 accidents with injuries (11 in 2024), 5 accidents with leave (6 in 2024), zero high-consequence work-related injuries and zero work-related deaths (S1-14/88, page 158). Third-party (value-chain) workers recorded 9 accidents with injuries and 8 with leave in 2025, versus 1 death due to accidents at work in 2024 and 2023 (page 158).

Work-life balance metrics

Reference: pages 159-160.

"Cellnex complies with current legislation on this matter in each of the countries in which it operates and guarantees family-related leave to all its employees (including maternity/paternity leave, among others)" (S1-15/91, page 159). Entitlement to family-related leave is 100% for both women and men in every reporting country.

Uptake of family-related leave in 2025 varied widely by country: Poland recorded 96% of women taking family-related leave versus 2% of men; Denmark recorded 17% of women versus 8% of men; Sweden 12% versus 8% (S1-15/93, page 159). This is disclosed at company-year level rather than for Cellnex Group as a whole; a Group-level aggregate figure was not found in the extracted text.

Compensation metrics (pay gap and total compensation)

Reference: pages 160-161.

Group unadjusted gender pay gap: average 9.3% in 2025 versus 9.0% in 2024; median -1.3% versus -0.6% (S1-16/97, page 161). Country figures vary widely: Spain shows a negative median gap (-8%) alongside a positive average gap (5%), meaning results differ by measure, while Italy and Portugal show the highest average gaps at 28% each. "A gender pay gap action plan continued to monitor and reduce overall and country pay gap, with a special focus in countries with gender pay gap >15% (unadjusted results)" (page 160).

CEO pay ratio versus average employee remuneration was 33.4 in 2025, down from 38.4 in 2024 (S1-16/97(b), page 161); CEO total remuneration was EUR 2,804,000 in 2025 versus EUR 3,109,951 in 2024. Average remuneration by professional category and gender is tabulated on page 161, though some categories are withheld due to confidentiality issues.

Incidents, complaints and severe human rights impacts

Reference: page 162.

"In 2025, two communications of potential incidents on discrimination, including harassment, were received through the Whistleblowing Channel... one closed in 2025, the other still in progress during 2026" (S1-17/103, page 162). The Group-wide Whistleblowing Channel logged 10 communications in total in 2025 (6 in 2024), spanning discrimination/harassment (2), conflicts of interest (3) and other inquiries (5); zero related to corruption/bribery, customer privacy or human rights (page 186).

"In 2025, Cellnex reported no serious human-rights incidents involving its employees, including forced labour, human trafficking or child labour... As no incidents were identified, no fines, compensation or remediation measures were required" (S1-17/104, page 162).

Policies related to value chain workers

Reference: page 164.

"The Board of Directors provides strategic oversight of human rights matters, embedding these principles into Cellnex's culture and operations and monitoring compliance" (S2-1/17, page 164). The Occupational Health & Safety and Human Rights Policies apply across the value chain, "aligned with international standards such as the UN Guiding Principles on Business and Human Rights, ILO conventions and OECD Guidelines" (page 164).

"Through the Occupational Health and Safety and Human Rights Policies, Cellnex firmly opposes trafficking in human beings, forced or compulsory labour and child labour across its value chain" (S2-1/18, page 164), reinforced by the Statement on Modern Slavery and Human Trafficking and 1,697 hours of human-rights-specific training in 2025. The Supplier Code of Conduct requires supplier compliance with human rights and health-and-safety standards (S2-1/19, page 164).

Processes for engaging with value chain workers about impacts

Reference: pages 164-165.

"Cellnex has established a Human Rights Due Diligence (HRDD) process, including a Human Rights Impact Assessment (HRIA), to identify, assess and monitor potential and actual human rights impacts affecting workers in its value chain" (S2-2/20, page 164-165), taking "relevant input from value chain workers or their representatives, including information obtained through assessments and interactions with business partners."

Engagement occurs directly during service delivery and indirectly through the Purchasing Department's procurement process (S2-2/22, page 165). "During the process of managing impacts along the value chain, special attention is taken to vulnerable groups as women, migrants and workers with disabilities" (S2-2/23, page 165). The company "is assessing the feasibility of establishing a global engagement process to collect worker perspectives consistently across locations" (S2-2/24, page 165).

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: page 165.

"Cellnex has a Human Rights Due Diligence and Human Rights Impact Assessment (HRIA), which considers the company's activities throughout the value chain. As part of this process, a map is made, which allows the company to classify actual or potential impacts and prioritise them by severity and probability" (S2-3/25, page 165).

"Whistleblowing Channel... may be used to raise human rights and labour-related concerns and potential or actual adverse impacts, not only breaches of law or internal policies" (S2-3/27, page 165). Submissions "may lead to corrective actions with suppliers and inform preventive measures within Cellnex's human rights due diligence and risk management processes" (S2-3/28, page 165).

Taking action on material impacts on value chain workers

Reference: pages 165-168.

Cellnex applies "a unified risk-management model, approved and overseen by the Audit and Risk Management Committee (ARMC)" to workplace safety in the value chain (S2-4/30-31, page 165), integrating OHS requirements into supplier procurement and qualification (S2-4/33-34, page 166). "In 2025, efforts have been focused on developing the coordination of business activities framework to manage access requests to company sites, ensuring compliance with OHS standards" (page 167).

Resources allocated include dedicated OHS teams, technological monitoring tools, and stakeholder engagement budgets (S2-4/38, page 168). "No severe human rights issues or incidents involving value-chain workers were reported during the reporting period" (S2-4/36, page 167); Cellnex states it would "document the case, investigate root causes and implement corrective actions with the relevant supplier" if one occurred.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: pages 168-169.

Value chain H&S targets for FY2025 (S2-5/39, page 168): "Zero-Accidents: No type A accidents in 2025"; "AFRL: Target <1; FY25 at 1.07 (employees) and 1.58 (supply chain)"; near-miss ratio "Target 3.5 by 2030; improved from 0.39 (2024) to 1.77 (2025)"; safety inspections in high-risk activities, "1,828 inspections... 31% more than in 2024," with a 2030 coverage goal of 5%; and Tier A/B hazardous-work-supplier ISO 45001 compliance, "improved from <70% in 2024 to ~80% in 2025," against a "90% compliance target by 2030."

Value-chain workers and representatives are engaged in target-setting and performance tracking "through regular meetings between H&S teams and workers' representatives" (S2-5/42, page 169).

Business conduct policies and corporate culture

Reference: pages 173-176.

"The Committee of Ethics and Compliance (CEC) is responsible for overseeing ethics, business integrity, and the effectiveness of the company's compliance system" (GOV-1/5(a), page 173), reporting to the Audit and Risk Management Committee. Core policies: the Code of Ethics (all employees), the Policy for the Whistleblowing Channel, and the Anti-Bribery, Gifts and Hospitality Policy (page 174), each with MDR-P scope, responsible-party and third-party-standards fields tabulated (page 174).

"In 2025, Cellnex has been recognized as the company with the highest level of transparency within the Technology and Telecommunications sector" per Fundacion Haz's 2025 Transparency and Good Governance Report (page 175). "93% of employees trained in Code of Ethics and anti-bribery policies" is reported as a 2025 KPI (page 171).

Management of relationships with suppliers

Reference: pages 176-181.

"Procurement decisions consider not only price and quality but also social, ethical, environmental and privacy criteria" under the Board-approved Procurement Policy and Supplier Code of Conduct (G1-2/12, page 176). Suppliers are tiered A/B/C by spend and criticality; "In 2025, Cellnex aimed to qualify 164 critical and relevant suppliers, distributed as follows: 20% tier A, 65% tier B, and 15% tier C," achieving "100%" assessment of all 164 (page 178).

Assessment figures: 295 suppliers environmentally assessed (89% of main suppliers, up from 219/90% in 2024); 347 socially assessed via EcoVadis (93%); "24" suppliers supported in corrective-action-plan implementation in 2025 (versus 5 in 2024), with an 89% completion rate (page 181). "95% of local suppliers" by count (page 182).

Prevention and detection of corruption and bribery

Reference: pages 183-185.

"Cellnex is committed to conducting its business with the highest standards of integrity... and has established a comprehensive system, the Anti-Bribery Management System (ABMS), aligned with the international standard ISO 37001" (G1-3/16, page 183). "In 2025, Cellnex has successfully completed the audits required for the continued maintenance of compliance with ISO 37001" (page 184).

Procedures cover prevention (Anti-Bribery, Gifts and Hospitality Policy plus a third-party compliance risk-assessment tool), independent investigation by the CEC, and outcome reporting to governance bodies (G1-3/18, page 184). Training: "Mandatory ethics and compliance training is provided to all employees" (G1-3/21(a), page 184), with a specific anti-bribery module for the Board of Directors.

Targets related to business conduct

Back-filled from the business conduct chapter's MDR-M/MDR-T table and 2025 KPI disclosures, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

A "Governance metrics and targets MDR-M / MDR-T" table (page 185) sets a compliance-training coverage target described as "80% of Cellnex Group and 100% of Executive Committee and Directors receiving compliance training," with 2024 performance of "93%/83%." Consistent with this, the 2025 KPI box reports "93% of employees trained in Code of Ethics and anti-bribery policies" and "0 incidents of corruption or bribery" for the year (page 171).

The Sustainability Master Plan 2030 carries forward a related forward-looking target: "≥95% employees trained in ethics, compliance and anti-bribery" (page 69), extending the existing compliance-training metric into the new plan.

Incidents of corruption or bribery

Reference: pages 185-187.

"Throughout the year, there were no convictions for violations of anti-bribery or anti-corruption laws... no fines related to such violations were imposed on Cellnex, and... there were no confirmed incidents of bribery or corruption involving employees or business partners. Consequently, no workers were dismissed or disciplined for corruption or bribery-related incidents, nor were any contracts with business partners terminated" (G1-4/24-26, page 186).

"The number of communications received through the Whistleblowing Channel in 2025 was 10 (6 in 2024)," none categorised as corruption or bribery (0 of 10) (page 186). "Additionally, no public legal cases regarding bribery or corruption were brought against the company or its employees during 2025" (page 186).

Payment practices

Reference: pages 188-189.

"Cellnex continuously adapts its internal payment processes, implementing measures to mitigate late payments in commercial transactions... in compliance with legal and tax requirements" (G1-6/31, page 188). "During 2025 there were no outstanding legal proceedings for late payments" (page 188).

Average number of days to pay invoices from the contractual/statutory term start, by country: France 53.27 days (standard term 45 days end-of-month) with 74% of payments aligned with standard terms; Spain 51.17 days (standard 60 days, 72% aligned); Poland 20.37 days (standard 60 days, 98% aligned); UK 24.73 days (standard 60 days, 95% aligned) (page 189).