4.4 Commitment to Human Rights

Cellnex is committed to respecting and promoting Human Rights in its business activities and value chain, including partners, employees and other stakeholders, using the core international standards as a benchmark. This was evidenced in March 2022 when Cellnex updated its Human Rights Policy, reaffirming its commitment to protect and respect universally recognised Human Rights within its sphere of influence and to mitigate and repair any damage that may be caused.

The benchmarks for the Policy are the core international standards that it has committed to fulfil, which it adopts as the regulatory framework to define the limits within which the company's activities must be conducted:

• UN International Bill of Human Rights
• The eight fundamental ILO conventions
• Guiding Principles of the UN Global Compact
• UN Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises
• United Nations Children's Rights and Business Principles

Moreover, the Cellnex Human Rights Policy is aligned and complemented with other Cellnex internal policies and regulations, such as the Environmental, Social and Governance (ESG) Policy, the Equity, Diversity and Inclusion Policy, the Supplier Code of Conduct, the Code of Ethics, the whistleblower channel and the Corruption Prevention procedure.

To obtain a more holistic understanding of its adverse impacts, Cellnex has assessed its Human Rights risks based on its business relationships along its value chain and how it relates to its stakeholders. This assessment aims to identify the most critical and highest priority actual and potential adverse impacts of Cellnex's context, based on the regulatory framework of the UN Guiding Principles on Business and Human Rights, which establish due diligence as an operating principle. As a result, Cellnex has a broader view to prevent and mitigate any negative impact of its activities on Human Rights, defining and implementing cross-cutting and specific actions. The due diligence is updated every year to deepen the protection of Human Rights.The Summary of the Human Rights Due Diligence and Assessment Process is available in the corporate website.

Although the European Union's Human Rights Due Diligence Directive has not yet been published, Cellnex has carried out an frontloading exercise, in which it also undertakes to share its progress in the observation and application of the Human Rights Principles on a regular basis with both internal and external stakeholders, thus upholding the principle of transparency. In this regard, the Risk Management department, in coordination with the Environment, Social and Governance department, is responsible for supervising the Human Rights due diligence process, with the participation of the various Company departments, and is also responsible for promoting, measuring and reporting on the development and application of the Human Rights Policy at local and global level.

In addition, in 2022 Cellnex published the Statement on Slavery and Human Trafficking, which declares that Cellnex condemns all exploitative labour practices, including the use of child labour, and that the company is fully committed to preventing them, both in the Group's spheres of influence and in all issues affecting its supply chain. Moreover, to prevent modern slavery, Cellnex has a Code of Ethics and a Whistleblowing Channel, and in early 2022 it adopted a Code of Conduct for Suppliers which acts as a framework of trust and cooperation for the Organisation and its value chain.

Specific training in Human Rights is also carried out, with a total of 3,845 hours devoted to training on human rights policies and procedures in the Group as a whole.

In 2022, as in 2021, there have been no reported incidents of discrimination.