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Corporate Social Responsibility Policy

Background

The Board of Directors of Cellnex Telecom, S.A. (“Cellnex Telecom”), is responsible for approving the Corporate Social Responsibility Policy (CSR) for the Cellnex Group.

In the performance of these duties, the Board of Directors approves this policy, and gathers the Company’s CRP strategy regarding the area of CRP and its commitment to the application of the best practices in the countries where the Cellnex Group operates and in line with the international reference standards.

1. Purpose and scope of application

1.1. Purpose.
This document establishes the basic guidelines and lines of action regarding the Cellnex Telecom’s Corporate Social Responsibility which allow the formalisation and implementation of the concept of CSR within the framework of the organisation, its communication thereof to stakeholders and the progressive systematisation in all systems and operational processes of the Cellnex Group.

 
1.2. Scope of application.
This policy mandatorily applies to all companies controlled by Cellnex Telecom (“Cellnex Group”).

Cellnex Group: Companies in which Cellnex Telecom, S.A. possesses or may possess, directly or indirectly, the control, where control means:

  • the ownership of the majority of the voting rights,
  • the ability to appoint or remove a majority of the members of the board of directors (or equivalent body), or
  • the ability to hold, by virtue of any agreements concluded with third parties, the majority of the voting rights.

2. Basic principles

The policy defined herein constitutes the minimum requirements to be met by all companies that operate under the umbrella of Cellnex Group. The chief executive of each company of Cellnex Group must ensure that internal regulations are developed and/or adapted in line with this policy and with any applicable legal regulations.

The CSR Policy is applicable to all the organisation’s activities and in all countries in which it operates both, directly and indirectly. It covers the entire life cycle of the Cellnex Group’s activity and complements the Group’s companies commitment to comply with the requirements of the legal framework in each country.

In accordance with the definition of CRS contained in the European Corporate Social Responsibility Strategy, CSR is an organisation’s responsibility for the impact of any nature of its activity on society and on its environment.

This policy is implemented within the following international standards of reference, which it also undertakes and adopts as regulatory framework of the limits under which the activity of the company shall be carried out:

  • Principles of the United Nations Global Compact (UN Global Compact).
  • Guiding Principles on Business and Human Rights (United Nations)
  • International Labour Organization’s (ILO) Fundamental
  • OECD Guidelines for Multinational Enterprises (OECD).

In line with these standards, in the specific management framework, Cellnex Telecom commits to comply with the SA8000 requirements, which applies to all Cellnex Group’s activity.

Similarly, in the setting of accountability, the standards of the Global Reporting Initiative (GRI), along with the technical equivalences to specific standards, constitute the Cellnex Group’s frame of reference, without prejudice to the inclusion of other complementary standards which may enhance the analysis and may be relevant for attaining the commitments outlined in this policy.

In accordance with these standards, Cellnex Telecom recognises two basic principles which apply transversally to all lines of action and commitments and upon which the implementation thereof is based:

  • Human Rights: The protection of and respect for universally recognised fundamental Human Rights, within the Cellnex Group’s sphere of influence, and non-complicity in the infringement thereof, as well as redressing the damages arising in the case of infringement.
  • Stakeholders: The identification of the organisation’s stakeholders, taking into consideration the entire value chain of the activity, the development of communications and participation channels and their direct and indirect involvement in the identification of material aspects and the assessment of the performance.

This policy is developed and supplemented through the internal regulations on Corporate Governance.

 3. Lines of action and commitments

The Cellnex Telecom´s CSR Policy is concretized, for its development and execution, in the CR Master Plan of the Cellnex Group. The current Master Plan, which covers the period 2016-2020 constitutes the working framework and tool for systematising the strategic objectives, the indicators linked to monitoring and the actions and programmes being developed for each of the areas of the Plan.

In this regard, the strategic areas which are contained in the CSR Master Plan, are the following:

  • Ethic Management and good corporate governance: to develop a culture that promotes the best practices of Corporate Governance, marked by the principles of efficiency, responsibility and alignment with principles and values based on respect, freedom of opinion, the integration of diversity of gender and race.
  • Development of people: to promote a quality employment; with a talent development plan to ensure competitiveness and sustainability of the Cellnex Group, as well as the own employability of their professionals; with appropriate policies accompanying the internationalization process of the Cellnex Group.
  • Sustainable Business Development: to promote a management of the operations focused on the principles of efficiency valorising and maximising the use and utilization of all resources, with special attention to the non-renewable, and adopting the criteria of circular economy. Also, to promote, in cooperation with the industry and academic and scientific institutions, the analysis and monitoring of the environmental impact linked to the development of the activity of the Cellnex Group.
  • Contribution of value to society: this is expressed in the support of innovation and entrepreneurship projects in the telecommunications sector; approximation to the third sector and the Public Administrations to support projects and initiatives in the field of digital inclusion; impulse and encouragement to responsible and local purchasing as expression of the tractor role of the Cellnex Group in relation to countries and territories in which it operates.
  • Communication and reporting: understood as a key factor in the creation of an environment of transparency in relation to the Cellnex Group, as well as an approach, knowledge and acknowledgment in relation to the stakeholders of Cellnex Telecom.
  • Governance of Corporate Responsibility: to provide the elements and necessary resources, both of supervision and control as well as executives, to ensure the development and implementation of the CR Master Plan and its update.

The monitoring of the implementation of actions linked to attaining the strategic objectives of the CSR Master Plan, along with the regular updating of material aspects and with the participation of stakeholders, will have an impact on the progress of the priority contents in each of the strategic areas.

The capacity to have an impact in the application of the policy, will vary on the basis of the existing management capacity, as well as on the stakeholders involved in each of the material aspects.

Moreover, each Business Unit and Functional Area, in coordination with the Department of Corporate and Public Affairs of Cellnex Telecom, is responsible for implementing the corresponding actions for compliance with the commitments outlined in this policy, as well as the specific linked procedures and regulations.

4. Monitoring and control

  • The Nominations and Remuneration Committee (NRC) of the Board of Directors, in accordance with the functions assigned in the Board of Directors’ Regulations, is the highest governing body responsible for ensuring compliance with the commitments established in this policy, as well as the actions which may derive from it. Similarly, such Committee is responsible for approving and monitoring the organisation’s material aspects in the area of CSR, as well as for monitoring the application of the CSR Master Plan.
  • Likewise, all areas and departments in Cellnex Telecom participate directly and indirectly in the implementation of specific actions and the monitoring thereof, in accordance with the corresponding sphere of competence and the relationship thereof with the material aspects of the CSR.
  • Annually, the entire organisation will be involved in process of collecting data and evidence of progress in the field of CSR, which are reflected in the Integrated Annual Report in which the results of the performance analysis are collected for each of the economic, environmental, social and good governance aspects.
  • The Integrated Annual Report is of a public nature, is prepared in accordance with the main international standards in the field and may be audited by an independent third party.


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