Annex 3. GRI Content Index

102-1

Name of the organisation

Cellnex Telecom, S.A.

Cellnex group

102-2

Activities, brands, products and services

2. Cellnex in 2019: milestones, key figures, business model & prospects / Business Model.

Cellnex group

102-3

Location of headquarters

Juan Esplandiú,

Cellnex group

28007 Madrid

102-4

Location of operations

2. Cellnex in 2019: milestones, key figures, business model & prospects / Milestones and main figures for the year 2019

·          Growth

·          Consolidation in Europe

Cellnex group

102-5

Ownership and legal form

Cellnex Telecom, S.A.

Cellnex group

102-6

Markets served

2. Cellnex in 2019: milestones, key figures, business model & prospects / Business Model.

2. Cellnex in 2019: milestones, key figures, business model & prospects / Milestones and main figures for the year 2019

·          Growth

·          Consolidation in Europe

Cellnex group

102-7

Size of the organisation

2. Cellnex in 2019: milestones, key figures, business model & prospects / Milestones and main figures for the year 2019

·          Growth

·          Consolidation in Europe

·          Market figures

·          Treasury share

·          Business performance and results

·          Business indicators

Cellnex group

102-8

Information about employees and other workers

4.Sustainable Management of the Value Chain / People Development / People management.

Annex 5. KPI Tables.

Cellnex group

102-9

Organisational structure, value chain, supply chain

2. Cellnex in 2019: milestones, key figures, business model & prospects / Milestones and main figures for the year 2019 / Transformation. Towards a new industrial model.

4.Sustainable Management of the Value Chain / Add value to society / Suppliers.

Cellnex group

102-10

Significant changes in the organisation and its supply chain

4.Sustainable Management of the Value Chain / Add value to society / Suppliers.

Cellnex group

102-11

Precautionary principle or approach

Cellnex has environmental liability insurance in compliance with current legislation and has a provision of 60,000 euros.

Cellnex group

2. Cellnex in 2019: milestones, key figures, business model & prospects / Milestones and main figures for the year 2019 / The Cellnex tax contribution/ Value generated and distributed.

4.Sustainable Management of the Value Chain / Sustainable development of the business / Monitoring and managing the main risks opportunities and environmental impacts.

102-12

External initiatives

4.Sustainable Management of the Value Chain / Add value to society / Cellnex's participation in relevant initiatives

·          Significant awards and recognition of Cellnex in 2019.

·          Cellnex's participation in Sustainability Indices and initiatives.

Cellnex group

102-13

Membership of associations

4.Sustainable Management of the Value Chain / Add value to society / Cellnex's participation in relevant initiatives / Cellnex action and participation in relevant industry associations.

Cellnex group

102-14

Declaration of senior executives responsible for decision-making

1.Interview with the President and CEO.

Cellnex group

102-15

Main impacts, risks and opportunities

3.Governance Model / Risk Management.

Annex 2. Risks

Cellnex group

102-16

Values, principles, standards, and norms of behaviour

3.Governance Model / Ethics and compliance.

Cellnex group

102-17

Mechanisms for assessment and complaint of ethical conduct

3.Governance Model / Ethics and compliance.

Cellnex group

102-18

Governance structure

3.Governance Model / Corporate governance.

Cellnex group

102-19

Delegation of authority

Section C of the 2019 Annual Corporate Governance Report (Annex 8).

Cellnex group

102-20

Executive responsibility for economic, environmental and social matters

3.Governance Model / Cellnex's Corporate Social Responsibility framework

Cellnex group

Section H of the 2019 Annual Corporate Governance Report (Annex 8)

102-21

Consultation with stakeholders on economic, environmental and social matters

5.Bases for the Preparation of the Report / Determining the content of the report.

Cellnex group

102-22

Composition of the highest governing body and its committees

3.Governance Model / Corporate governance / The Cellnex Board of Directors.

Sections C1.2, C1.3 Y C2 of the 2019 Annual Corporate Governance Report (Annex 8)

Cellnex group

102-23

Chair of the highest governing body

3.Governance Model / Corporate governance / The Cellnex Board of Directors.

Cellnex group

102-24

Appointment and selection of the highest governing body

3.Governance Model / Corporate governance / Changes in 2019.

Cellnex group

102-25

Conflicts of interest

Section D of the 2019 Annual Corporate Governance Report (Annex 8)

Cellnex group

102-26

Role of highest governance body in setting purpose, values, and strategy

Section C of the 2019 Annual Corporate Governance Report (Annex 8)

Cellnex group

102-27

Collective knowledge of the highest governing body

3.Governance Model / Corporate governance.

Cellnex group

102-28

Evaluation of the performance of the highest governance body

3.Governance Model / Corporate governance.

Section C.17 of the 2019 Annual Corporate Governance Report (Annex 8)

Cellnex group

102-29

Identification and management of economic, environmental and social impacts

3.Governance Model / Risk Management.

Annex 2. Risks

Cellnex group

3.Governance Model / Cellnex's Corporate Social Responsibility framework

102-30

Effectiveness of risk management processes

3.Governance Model / Risk Management.

Annex 2. Risks

Cellnex group

102-31

Review of economic, environmental, and social topics

3.Governance Model / Risk Management.

Annex 2. Risks

Cellnex group

3.Governance Model / Cellnex's Corporate Social Responsibility framework

102-32

Highest governance body’s role in sustainability reporting

3.Governance Model / Cellnex's Corporate Social Responsibility framework

Cellnex group

Section H of the 2019 Annual Corporate Governance Report (Annex 8)

102-33

Communicating critical concerns

3.Governance Model / Ethics and compliance.

Cellnex group

102-34

Nature and total number of critical concerns

3.Governance Model / Ethics and compliance.

Cellnex group

102-35

Remuneration policies

Section C of the 2019 Annual Corporate Governance Report (Annex 8)

Cellnex group

102-36

Process for determining remuneration

Section C of the 2019 Annual Corporate Governance Report (Annex 8)

Cellnex group

102-37

Stakeholders’ involvement in remuneration

Section A of the 2019 Annual Report on Remuneration Policy of Board Members

Cellnex group

102-38

Annual total compensation ratio

The salary of the highest paid person not including the CEO is 81.27 times higher than the average Cellnex group salary. The ratio is 42.68.

Cellnex group

102-39

Ratio of the percentage increase in total annual compensation

The variation in the average remuneration of the Group in relation to 2019 was -4%, and the variation in the remuneration of the CEO was 97.5%. The changes correspond to the total remuneration accrued, excluding contributions to pension funds and life insurance premiums.

Cellnex group

102-40

List of stakeholder groups

5.Bases for the Preparation of the Report / Determining the content of the report.

Cellnex group

102-41

Collective bargaining agreements

Annex 5. KPI tables.

Cellnex group

102-42

Identifying and selecting stakeholders

5.Bases for the Preparation of the Report / Determining the content of the report.

Cellnex group

102-43

Approach to stakeholder engagement

5.Bases for the Preparation of the Report / Determining the content of the report.

Cellnex group

102-44

Key topics and concerns raised

5.Bases for the Preparation of the Report / Determining the content of the report.

Cellnex group

102-45

Entities included in the consolidated financial statements

Consolidated Annual Accounts
(Annex 1)

Cellnex group

102-46

Defining report content and topic boundaries

5.Bases for the Preparation of the Report

·          Structure and content of the report.

·          Reporting scope.

·          Determining the content of the report.

Cellnex group

102-47

List of material topics

5.Bases for the Preparation of the Report / Determining the content of the report.

Cellnex group

102-48

Restatements of information

There have been no restatements of information from previous reports.

Cellnex group

102-49

Changes in reporting

The information in this report refers to Cellnex Spain, Italy, France, Switzerland, UK and Netherlands, with the exception of the template breakdown information which also includes data from Cellnex Ireland and Portugal.

Cellnex group

5.Bases for the Preparation of the Report

102-50

Period covered by the report

Financial Year 2019

Cellnex group

102-51

Date of the last report

2018

Cellnex group

102-52

Reporting cycle

Annual

Cellnex group

102-53

Contact person for queries regarding the report

5.Bases for the Preparation of the Report / Contact information (cellnex@cellnextelecom.com)

Cellnex group

102-54

Claims of reporting in accordance with the GRI Standards

5.Bases for the Preparation of the Report / Structure and content of the report.

Cellnex group

102-55

GRI content index

Annex 3. GRI Context Index

Cellnex group

102-56

External assurance

Annex 6. Independent Limited Verification Report

Cellnex group

103-1 [1]

Explanation of the material topic and its Boundary

5.Bases for the Preparation of the Report

·          Reporting scope.

·          Determining the content of the report.

Cellnex group

103-2⁽¹⁾

The management approach and its components

103-3⁽¹⁾

Evaluation of the management approach

201-1

Direct economic value generated and distributed

2.Cellnex in 2019: milestones, key figures, business model & prospects / Milestones and main figures for the year 2019 / The Cellnex tax contribution.

Cellnex group

202-2

Proportion of senior executives hired from the local community

100% of Cellnex Spain management comes from the local community.

Spain

203-1

Investments in infrastructure and supported services

2.Cellnex in 2019: milestones, key figures, business model & prospects

·          Business performance and results.

·          Business indicators.

Cellnex group

204-1

Proportion of procurement from local suppliers

4.Sustainable Management of the Value Chain / Add value to society / Suppliers.

Spain / Italy/ France/ Switzerland

205-2

Communication and training about anti-corruption policies and procedures

3.Governance Model / Ethics and compliance / Main responsibilities of Cellnex’s Committee of Ethics and Compliance.

The money-laundering issue is addressed in the Cellnex Corruption Prevention Procedure.

Cellnex group

205-3

Confirmed incidents of corruption and actions taken

3.Governance Model / Ethics and compliance / Main responsibilities of Cellnex’s Ethics and Compliance Committee.

Cellnex group

206-1

Legal actions for anti-competitive behaviour, anti-trust, and monopoly practices

In FY 2019, Cellnex received no complaints for anti-competitive or monopolistic practices, nor have the market or competition supervisory authorities initiated procedures ex officio. Likewise, it received no final judgments or any other type of sanction for such practices. See note 18.c) to the Consolidated Financial Statements.

Cellnex group

302-1

Energy consumption in the organisation

4.Sustainable Management of the Value Chain / Sustainable development of the business / Sustainable use of resources.

Cellnex group

302-2

Energy consumption outside the organisation

4.Sustainable Management of the Value Chain / Sustainable development of the business / Sustainable use of resources.

Cellnex considers all the energy consumed in its operating facilities as internal consumption.

Cellnex group

302-4

Reduction of energy consumption

4.Sustainable Management of the Value Chain / Sustainable development of the business / Sustainable use of resources / Energy efficiency.

Cellnex group

304-1

Operational sites owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas

4.Sustainable Management of the Value Chain / Sustainable development of the business / Biodiversity.

Spain / Italy / Netherlands

304-2

Significant impacts of activities, products and services on biodiversity

4.Sustainable Management of the Value Chain / Sustainable development of the business / Biodiversity.

Spain / Italy / Netherlands

305-1

Direct GHG emissions (scope 1)

4.Sustainable Management of the Value Chain / Sustainable development of the business / Carbon footprint and climate change.

Cellnex group

305-2

Indirect GHG emissions when generating energy (scope 2)

4.Sustainable Management of the Value Chain / Sustainable development of the business / Carbon footprint and climate change.

Cellnex group

305-3

Other indirect GHG emissions (scope 3)

4.Sustainable Management of the Value Chain / Sustainable development of the business / Carbon footprint and climate change.

Cellnex group

305-5

Reduction of GHG emissions

4.Sustainable Management of the Value Chain / Sustainable development of the business

·          Sustainable use of resources.

·          Carbon footprint and climate change.

Cellnex group

307-1

Non-compliance with environmental laws and regulations

There were no environmental complaints in 2019.

Cellnex group

308-1

New suppliers that were screened using environmental criteria

4.Sustainable Management of the Value Chain / Add value to society / Suppliers / Evaluation, selection and monitoring of suppliers.

Spain / Italy / France/ Switzerland

401-1

New employee hires and employee turnover

Annex 5. KPI Tables    

Cellnex group

402-1

Minimum notice periods regarding operational changes

Cellnex Spain: 2 weeks, following the established pre-notification periods.

Cellnex group

Cellnex Italia follows the periods laid down in the agreement of the Telecommunications Collective.

Cellnex France: varies between 1 and 3 months, depending on the case.

In Switzerland, the Netherlands and the UK, we comply with the minimum notice periods established by local law in each case.

403-1

Worker representation on formal worker-company health and safety committees

4.Sustainable Management of the Value Chain / People development / Occupational health and safety.

Spain / Italy

403-2

Types of injury and rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities

Annex 5. KPI Tables

Cellnex Group

4.Sustainable Management of the Value Chain / People development / Occupational health and safety / Accident rate.

403-4

Health and safety topics covered in formal agreements

with trade unions

4.Sustainable Management of the Value Chain / People development / Occupational health and safety.

Spain / Italy

404-1

Average hours of training per year per employee

Annex 5. KPI Tables

Cellnex group

4. Sustainable Management of the Value Chain / People development / Training.

404-2

Programmes to improve employee skills and transition assistance programmes

4.Sustainable Management of the Value Chain / People development / Training.

Cellnex group

405-1

Diversity of governing bodies and employees

During 2019, Cellnex has employed 14 people with different capacities.

Cellnex group

Annex 5. KPI Tables

 3.Governance Model / Corporate governance.

405-2

Ratio of basic salary and remuneration of women to men

Annex 5. KPI Tables

Cellnex group

406-1

Incidents of discrimination and corrective actions taken

3. Governance Model / Ethics and compliance / Main responsibilities of Cellnex’s Ethics and Compliance Committee.

Cellnex group

407-1

Operations and suppliers in which the right to freedom of association and collective bargaining may be at risk

3. Governance Model

·          Ethics and compliance

·          Cellnex's Corporate Social Responsibility framework.

4.Sustainable Management of the Value Chain / Add value to society / Suppliers

Cellnex group

408-1

Operations and suppliers with significant risk of using child labour

3. Governance Model

·          Ethics and compliance

·          Cellnex's Corporate Social Responsibility framework.

4.Sustainable Management of the Value Chain / Add value to society / Suppliers

Cellnex group

409-1

Operations and suppliers at significant risk for incidents of child labour

3. Governance Model

·          Ethics and compliance

·          Cellnex's Corporate Social Responsibility framework.

4.Sustainable Management of the Value Chain / Add value to society / Suppliers

Cellnex group

412-2

Employee training on human rights policies or procedures

Cellnex has dedicated 2,369 hours in human rights training.

Cellnex group

413-1

Operations with local community engagement, impact assessments,

and development programmes

4.Sustainable Management of the Value Chain / Add value to society / Social contribution / Donations.

4.Sustainable Management of the Value Chain / Sustainable development of the business / Electromagnetic emissions

Cellnex group

414-1

New suppliers that were screened using social criteria.

4.Sustainable Management of the Value Chain / Add value to society / Suppliers / Evaluation, selection and monitoring of suppliers.

Spain / Italy / France/ Switzerland

415-1

Political contributions

Only financial contributions have been made only by Cellnex France, to an entity dedicated to the lobbying body (Boury Tallon), to the tune of € 72.354,31.

Cellnex group

416-1

Assessment of the health and safety impacts of product and service categories

4.Sustainable Management of the Value Chain / Add value to society

·          Information security management.

·          Customers.

Cellnex group

418-1

Substantiated complaints concerning breaches of customer privacy and losses of customer data

4.Sustainable Management of the Value Chain / Add value to society / Information security management.

Cellnex group

419-1

Non-compliance with laws and regulations in the social and economic area

During the financial year of 2019, a ruling has been issued, which has become final, rejecting Cellnex's contentious appeal against the sanction (Bellaterra-Sabadell Center) in the form of a fine imposed by the State Aviation Safety Agency for infractions typified in Law 21/2003, of July 7, on Air Safety.

Cellnex group