Regulation (EU) 2020/852 established a phased implementation of the regulation, starting with simpler regulatory requirements in 2022 and expanding them from January 2023. From January 1, 2023, all obligations come into force of disclosure of the Taxonomy for the objectives of Mitigation and Adaptation, obliging to report based on Annexes I and II of the Delegated Act of Article 8 (2021/4987/UE). It is then obliged to report alignment, in addition to the eligibility of economic activities at the level of financial data, with all that is involved in quantitative and qualitative verifications for technical selection criteria, Do Not Significant Harm (DNSH) and minimum guarantees.
Consequently, following the regulations that apply from 2023, the analysis of eligibility and alignment of economic activities and calculations of the KPIs to be disclosed this year with data from 2022 have been developed, explaining the reasoning and approaches used during the study.
This section aims to provide details on how the calculation process of the different indicators of the Taxonomy has been proposed, based on the economic-financial data, and the phases that have been established in the process. This exercise is based on the taxonomy project carried out since 2021 in preparation for the disclosure of information on the indicators linked to the taxonomy in the Integrated Annual Report for 2021 and 2022.
The process followed to obtain the degree of alignment based on Taxonomy Regulation 852/2020/UE has followed the following steps:
In each of the phases, the data and the appropriate quantitative and qualitative evidence have been compiled for subsequent external verification.
The identification of large business units is based on the one developed last year with the confirmation and validation of the different business managers. Among these were identified:
The result of this analysis was a list of specific economic activities for each of the three large branches described, providing definitions for each of them and the necessary details to define a specific NACE.
Telecommunications infrastructure services |
Broadcasting infrastructure |
Other network services |
TIS |
Broadcast |
IoT |
5G |
Internet Media |
Smart Services |
Engineering Services |
|
MCPN |
Fiber |
|
Connectivity |
Utility fee |
|
O&M |
LTE |
|
Other income |
Pass through |
|
|
Others TIS |
|
|
DAS BL |
|
|
Land Aggreg. |
|
|
Datacenters |
|
|
This degree of detail allowed us to begin to consider the fit of the different business units with the statistical definitions of the different economic activities.
Based on the identification of the different economic activities and their respective description, the NACE code was assigned according to each of them. This code, together with the definition of each activity, was used as a basis for the eligibility analysis.
In the eligibility and alignment analysis, the activities have been differentiated and classified according to the KPIs analyzed (operating income, Capex and Opex) since some activities only appear in one of the defined items. The Opex KPI is not shown in the following sections because it has been considered as a non-material indicator. As established in Annex I of the Delegated Disclosure Act (Art. 8) referring to regulation 2020/852/UE, in point 1.1.3.2, those non-financial companies that consider that Opex is not a material indicator for their model of business, are exempt from calculating the numerator of the Opex KPI. The company considers that the Opex margin for the calculation of the Taxonomy is not material, mainly and in accordance with IFRS16 accounting regulations, the most significant item (rental costs) is reflected in financial interests and in the amortization of the financial statements of the company. Therefore, this causes the company to have very high operating leverage and margin.
For each of the business activities, it was validated if they really fit with the activities of the proposed Taxonomy. The approach to this task helped to outline the finally eligible activities in relation to those incorporated in the Climate Delegated Act.
In this second year of validation of eligibility for the economic activities carried out by Cellnex, the following list was defined:
Business Unit |
Eligibility based on Taxonomy (Activity) |
Environmental objective |
Activity typology |
Datacenters |
8.1. Data processing, hosting and related activities |
CC Mitigation |
Transition |
Broadcast |
8.3. Radio and television programming and broadcasting activities |
CC adaptation |
Adapted |
Internet Media |
8.3. Radio and television programming and broadcasting activities |
CC adaptation |
Adapted |
IoT Utilities |
7.5 Installation, maintenance and repair of instruments and devices to measure, regulate and control the energy efficiency of buildings (b) (Part related to electronic water meters) |
CC Mitigation |
Facilitator |
IoT Smart Services |
8.2 Data-driven solutions to reduce greenhouse gas emissions |
CC Mitigation |
Facilitator |
Mission Critical (MCPN) |
8.3 Radio and television programming and broadcasting activities (5.a) (Related to emergency telecommunication services that increase resilience to climate risks) |
CC adaptation |
Adapted Facilitator |
As regards Cellnex's operating income, the specific economic activities included in the headings of Telecommunications Infrastructures, Broadcasting Infrastructures and other network services have been considered. The following table shows the adjusted EBITDA items of the different lines as published in the annual accounts.
Operating income (Thousands of Euros) |
||
|
31 December 2022 |
31 December 2021 |
Telecommunications Infrastructure Services |
3,159,629 |
2,211,789 |
Broadcast Infrastructures |
223,497 |
218,290 |
Other network services |
112,054 |
102,720 |
Operating income |
3,495,180 |
2,532,799 |
Income by type (Thousands of Euros) |
||
|
31 December 2022 |
31 December 2021 |
Services |
3,251,155 |
2,441,669 |
Other operating income |
247,467 |
94,399 |
Advances to customers (Note 13.b) |
(3,442) |
(3,269) |
Operating Income |
3,495,180 |
2,532,799 |
If we now focus on the reason why each of the activities has been considered eligible, we must take into account the following points:
The most relevant revenue item for the group, Telecommunications Infrastructure Services (TIS), 67% of sales, could not be included in the eligibility calculations given that within the environmentally sustainable economic activities presented in the regulation. There is still no activity in line with that carried out by Cellnex. TIS's activity is based on the operational efficiency of telecommunications towers, an activity with a great positive impact as described above. The non-incorporation of environmentally sustainable services linked to connectivity through wireless and wired networks is surprising, a significant loss in the evaluation of the environmental sustainability of Cellnex's business. The lack of development of the Taxonomy damages the transparency of a company whose main business is linked to efficiency.
The numerator of the Capex indicator, which must be reported according to the Taxonomy regulations, establishes that the following investments can be counted as eligible/aligned:
In general, Cellnex distinguishes its investments in:
Investment (Thousands of Euros) |
||
Capital expenditures |
31 December 2022 |
31 December 2021 restated |
Maintenance capital expenditures |
107,726 |
76,799 |
Expansion (or organic growth) capital expenditures |
349,553 |
233,107 |
Expansion capital expenditures (Build to Suit programs) and Remedies |
2,133,206 |
1,346,136 |
Expansion capital expenditures (Build to Suit programs) |
2,282,650 |
1,346,136 |
Remedies (2) |
(149,444) |
— |
M&A capital expenditures |
4,881,163 |
12,741,420 |
Total investment (1) |
7,471,648 |
14,397,463 |
(1)“Total Investment”, amounting to €7,472Mn (€14,397Mn in 2021), corresponds to “Total net cash flow from investment activities” in the accompanying Consolidated Statement of Cash Flows amounting to €5,950Mn (€13,904Mn in 2021), plus i) “Cash and cash equivalents” of the acquired companies in business combinations amounting to €101Mn (€211Mn in 2021, see Note 8 to the accompanying consolidated financial statements); plus ii) "Cash advances to landlords" amounting to €133Mn (€71Mn in 2021, see Note 16 to the accompanying Consolidated Financial Statements); plus iii) the payment for the Hutchison UK acquisition through Cellnex Telecom SA shares (€1,237Mn, see Note 6 to the accompanying consolidated financial statements); plus iv) "Others" amounting to €51Mn (€210Mn in 2021), which includes, mainly, timing effects related to assets purchases, the reimbursement of contributions of the initial investment in DIV (€52Mn, see note 10 to the accompanying Consolidated Financial Statements) and other financial assets (€-93Mn, see note 13.b to the accompanying Consolidated Financial Statements).
(2) Corresponds to the total price in relation to the Divestment Remedy with WIG in the United Kingdom.
For each of these categories, the specific investment items have been identified that, after a fit analysis with the definitions, are considered eligible. Most of these come from investments in expansion and maintenance of eligible activities, however, investments in outputs from alienated activities are also added. Below is the corresponding table:
Investment item |
Activity |
Typology |
Datacentres |
Activity 8.1. - Climate Change Mitigation |
Aligned assets |
IoT Utilities |
Activity 7.5 - Climate Change Mitigation |
Aligned activities |
IoT Smart Services |
Activity 8.2 - Climate Change Mitigation |
Aligned activities |
Mission Critical |
Activity 8.3 - Adaptation to Climate Change |
Aligned activities |
Investment item |
Activity |
Typology |
Energy efficiency |
Activity 7.3. - Climate Change Mitigation |
Output activity aligned |
Renewable energy |
Activity 7.6. - Climate Change Mitigation |
Output activity aligned |
Although the eligible activities have been defined in the previous income section, some of which are listed in the table above, two new activities have been included for the Capex indicator.
In this phase, the requirements established in Article 3 of Regulation 2020/852/EU for an activity to be considered environmentally sustainable have been assessed. In addition to the point of contributing to one or more environmental objectives that has been previously assessed (Eligibility), compliance with the rest of the criteria has been verified:
The four points established in Art.3 must be met simultaneously for an activity to be considered environmentally sustainable. To analyze the degree of alignment of each activity, an eligibility screening was first carried out and then a verification of compliance with the criteria for Do Not Significant Harm (DNSH), minimum guarantees and Technical Selection Criteria (TSC). To ensure a correct alignment analysis, Cellnex has exhaustively examined these criteria and points, working in parallel to meet each of the points that the alignment process marks.
The technical selection criteria (TSC) and DNSH principles of each of the activities identified as eligible for Cellnex are analysed below.
Business Unit |
Eligibility based on Taxonomy (Activity) |
Environmental objective |
Activity typology |
Datacenters |
8.1. Data processing, hosting and related activities |
CC Mitigation |
Transition |
Cellnex has data centers in Spain, France and the Netherlands, the latter two countries having the bulk of centers. To comply with the first CTS, a working group was organized that analysed in detail the European Code of Conduct on energy efficiency in data centers, starting with the document 2022 Best Practice Guidelines for the EU Code of Conduct on Data Center Energy Efficiency, the Participant Guidelines v.3.0.0 and Reporting Form 13.2 spreadsheet. Once the requirements established for participants with underwriter characteristics, such as Cellnex, were analysed, a meeting was held with the heads of the Joint Research Center, who served as a guide to fill out the best practices questionnaire and ensure compliance with the better practices.
Once the questionnaires were filled out with their corresponding data, the information was provided to the auditor to verify compliance with the best practices in energy efficiency and ensure compliance with said TSC for those centers that had the technical characteristics and basic information to demonstrate the alignment.
Thanks to the refrigerant gas data collected for the calculation of the carbon footprint verified under the ISO 14064 standard, it was possible to analyse the data centers that totally or partially had refrigerant gases with a global warming value (GWP) less than or equal to 675. Some data centers have several refrigeration equipment to cool the different rooms of the building, therefore, for those centers where the gases that met the criteria did not represent the total number of gases, partial allocations of alignment have been made based on to the weight of the refrigerant gases.
The explanation of each point of the DNSH that proceeds for the activity is shown below:
Cellnex has carried out a Climate Change Adaptation Plan during 2022 that has two different parts, (i) a first focused on analyzing the climate risk of all its assets, and (ii) a second focused on proposing adaptation activities and proposals to those assets at risk. In general, the project has followed 5 steps:
The specific result obtained for data centers has been used to define the final alignment degree.
Cellnex's Water Availability Footprint, based on ISO 14046:2018, analyses the availability, consumption and impact on water masses. The analysis includes companies that incorporate data centers (Towerlink France S.A.S, Alticom B.V, On Tower Telecom Infraestructuras S.A.U) analysing whether consumption and the impact on water bodies is relevant to the activity, as well as direct and indirect consumption . From the result of the Water Availability Footprint, it is defined that only 0.02% is linked to a direct impact on the operations of the assets. Based on the results of the study, it has been considered that water consumption is not material for the business, also extending it to data centers, many with a lower consumption or comparable to a home due to the fact that they do not use open water circuits. for refrigeration.
Regarding the Environmental Impact Study, according to the transposition of Directive 2011/92/UE on EIAs, all the studies include a mandatory analysis of the environmental water vector, assessing potential physical and biological impacts.
Cellnex is a neutral infrastructure operator that offers control and management of space (data centre) by measuring temperature, humidity, providing energy, without installing its own equipment, allowing customers to have a space to install their servers. Thus, this category would apply to the server operators and not to the space managed by Cellnex.
For Cellnex control products in the data centers, the restricted substances in point 2 are complied with since the purchasing team has approved only products that have the CE label and specific sustainability labels, which certify compliance with the limits. of halogen materials according to Directive 2011/65/UE and Royal Decree 219/2013 that transposes it to the Spanish legal system.
Within its ISO 14001 environmental management system, Cellnex has a procedure specifically focused on waste management, which is implemented in all the countries where it operates and is mandatory for its own centers and suppliers that carry out waste management tasks. waste outsourced. At the same time, said procedure establishes clear guidelines to focus the waste generated on a management that prepares it for its reuse, recovery or recycling.
Based on the eliminative criteria linked to the TSC and DNSH, financial data will be extracted only from data centers that meet all the criteria established to be considered aligned.
Cellnex offers data network services dedicated to the Internet of Things in different European countries. The benefits of IoT solutions achieve improvements with low consumption, long reach, low traffic and low cost for customers. In all projects, secure and resilient data communication is provided by collaborative cell designs and random frequency transmission. End-to-end services ultimately achieve an optimal transversal service for resource management and efficiency in all areas of management.
Within the IoT business, although many of the services have implicit characteristics that improve management from an environmental point of view, only services offered to public administrations or energy or natural resource service companies are considered for sustainability purposes.
Business Unit |
Eligibility based on Taxonomy (Activity) |
Environmental objective |
Activity typology |
IoT Utilities |
7.5 Installation, maintenance and repair of instruments and devices |
CC Mitigation |
Mitigation Facilitator |
The activity fits into the following individual measures:
If we focus on services to energy service companies and natural resources, Cellnex provides services to remotely control the consumption or flow of these in different types of solutions, mainly in buildings. The use of this type of solution is fantastic for smart meters, for example water or natural gas, where real-time and low-cost readings are needed to more efficiently manage the provider's infrastructures, optimizing their operations (reducing energy consumption and footprint). carbon) and improving efficiency in use by the end customer, avoiding excessive consumption.
The explanation of each point of the DNSH that proceeds for the activity is shown below:
Cellnex has carried out a Climate Change Adaptation Plan during 2022 that has two different parts, (i) a first focused on analysing the climate risk of all its assets, and (ii) a second focused on proposing adaptation activities and proposals to those assets at risk. For the IoT Utilities business, the percentage of assets adapted to climate change linked to the transmission of information has been valued, considering the rest as non-aligned.
To obtain the financial data for this line of business, a detailed analysis of all the projects linked to this activity was made based on the information extracted from SAP by the financial department. Once the first list of projects with income computed in 2022 was obtained, meetings were held with those responsible for the business to analyse whether the services offered to each specific client fit the definition established in the Taxonomy regulation.
Business Unit |
Eligibility based on Taxonomy (Activity) |
Environmental objective |
Activity typology |
IoT Smart Services |
8.2. Data-driven solutions to reduce GHG emissions |
CC Mitigation |
Mitigation Facilitator |
The digital solution offered by Cellnex is an integrated information management tool with the aim of improving energy efficiency, reducing the consumption of natural resources and, consequently, reducing greenhouse gas emissions (Smart Cities or Smart Regions).
If we focus on services to public administrations or private entities, these are focused on the creation of Smart cities, Smart regions or Smart Companies depending on the client in question. A smart city goes beyond the use of digital technologies for a better use of resources and the reduction of emissions. It means smarter urban transportation networks, improved water supply and waste disposal facilities, and more efficient ways to light and heat buildings, as well as energy services.
Cellnex services include sensor networks and the integration of other data sources in transversal management systems to improve mobility management, increase energy efficiency, reduce resource consumption, improve waste management or reduce air pollution. . The establishment of indicators to assess changes in environmental vectors and ensure compliance with climate objectives in the short, medium and long term, is one of the services provided as a public administration tool. Private companies are more focused on improving efficiency in the use of energy linked to the production of renewable energy or air quality controls. In this way, the administration and private companies can use reliable and real-time data, processed by Cellnex, to make decisions that reduce greenhouse gas emissions.
Through the data, reports and results of the implemented projects, it has been considered proven that the activity complies with the established technical selection criteria.
The explanation of each point of the DNSH that proceeds for the activity is shown below:
In a general way, the IoT – Smart Services activity implements sensor networks for the integration of other data sources in transversal management systems, generating two types of physical climate risk to the activity, a first linked to the risks for the management of this type of project at the corporate level, and another linked to the networks or sensors implemented. Next, the aspects related to climate change are established;
As previously mentioned, Cellnex has carried out a Climate Change Adaptation Plan during 2022 that has analysed the degree of adaptation of the company. Since the IoT Smart Services activity involves different company assets, it has been considered aligned to the same degree as the company as a whole.
At the same time, the IoT Smart Services activity uses a catalogue of sensors with different characteristics, which are selected to ensure that they adapt to the weather conditions of the location where they are installed. It is for this reason that they have indoor or outdoor sensors, varying the degree of protection to climatic variables depending on the sensor. For example, for specific sensors of flood signals, the equipment is adapted to extreme conditions of precipitation or fluvial flooding that allow them to send data in extreme cases.
All electronic products purchased by Cellnex follow a green purchasing procedure that values aspects of sustainability, requires maximum compliance with regulations and voluntary recommendations, and ensures the best technical performance. Throughout the process, it is ensured that the restricted substances in point 2 are complied with, since the purchasing team has approved only products that have the CE label and other sustainability labels that ensure compliance with the limits of halogen materials according to the 2011 Directive. /65/UE and Royal Decree 219/2013 that transposes it to the Spanish legal system.
Within its ISO 14001 environmental management system, Cellnex has a procedure specifically focused on waste management, which is implemented in all the countries where it operates and is mandatory for its own centers and suppliers that carry out waste management tasks. waste outsourced. At the same time, said procedure establishes clear guidelines to focus the waste generated on a management that prepares it for its reuse, recovery or recycling.
To obtain the financial data for this line of business, a detailed analysis of all the projects linked to this activity was made based on the information extracted from SAP by the financial department. Once the first list of projects with income computed in 2022 was obtained, meetings were held with those responsible for the business to analyse whether the services offered to each specific client fit the definition established in the Taxonomy regulation.
Business Unit |
Eligibility based on Taxonomy (Activity) |
Environmental objective |
Activity typology |
Broadcast |
8.3. Radio and television programming and broadcasting activities |
CC adaptation |
Adapted to climate change |
The activity carried out by Cellnex de Broadcast is directly related to radio and television broadcasting services, an aspect incorporated in the definition of activity 8.3 Radio and television programming and broadcasting activities. This line of business is based on the broadcast of third-party television signals from Cellnex's telecommunications infrastructures, the company being a key player for companies and individuals to receive the corresponding signals.
The activity is considered almost fully aligned based on the results obtained in the climate risk analysis and the company's climate change adaptation plan. The result of said analysis establishes that between 97% - 90% of the company's telecommunications towers are at a risk level without the need to implement adaptation measures. The 3% - 10% could require some specific measure that will be worked on with the operations teams based on the results of the Climate Change Adaptation Plan.
The income derived from this activity has not been accounted for in the income indicator (%) since it is considered, at an accounting level, income from an "adapted" activity and cannot be included in the numerator as established in the Delegated Disclosure Act 2021/4987/UE.
Business Unit |
Eligibility based on Taxonomy (Activity) |
Environmental objective |
Activity typology |
Internet media |
8.3. Radio and television programming and broadcasting activities |
CC adaptation |
Adapted to climate change |
The activity carried out by Cellnex for Internet Media is directly related to services for broadcasting radio and television via the Internet, an aspect incorporated in the definition of activity 8.3 Radio and television programming and broadcasting activities. This line of business is based on the broadcast through digital platforms of third-party television signals from telecommunications infrastructures.
An example of the Internet Media business is the LOVEStv platform, the new DTT audiovisual platform adapted to new consumption habits. Cellnex Telecom is the technology provider of the platform that the Spanish public channel RTVE and the two large private broadcasting groups, Atresmedia and Mediaset, are working together to launch. This platform, which allows viewers to enjoy the advantages of linear DTT while being able to access content and new non-linear services.
As previously mentioned, Cellnex has carried out a Climate Change Adaptation Plan during 2022 that has analyzed the degree of adaptation of the company. Since Internet Media activity involves different company assets, it has been considered aligned to the same degree as the company as a whole.
The income derived from this activity has not been accounted for in the income indicator (%) since it is considered, at an accounting level, income from an "adapted" activity and cannot be included in the numerator as established in the Delegated Disclosure Act 2021/4987/UE.
Business Unit |
Eligibility based on Taxonomy (Activity) |
Environmental objective |
Activity typology |
Mission Critical |
8.3. Radio and television programming and broadcasting activities |
CC adaptation |
Climate change facilitator |
MCPN stands for Mission Critical and Private Networks. The business is based on the construction and operation of private communication networks, for limited and known users for security and efficiency reasons. The business is clearly divided into two parts, the networks called Mission Critical (Emergency Corps) and the networks called Private Networks (Business Sector).
The Mission Critical Networks are those of interest in terms of sustainability, since they are offered to emergency public services such as firefighters, civil protection, forestry agents, police, or medical services. The network technology offered can be Narrowband (TETRA, DMR) or Broadband (4G/5G), depending on the customer's needs. These private networks provide highly reliable and secure radio communication services to public emergency services that are used above all in extreme circumstances such as natural disasters (floods, storms, forest fires, etc.), accidents such as oil spills or gas leaks, etc
Mission Critical's activity has as a priority objective to offer communication services to emergency services to increase resilience to physical climate risks of people, nature, cultural property and private assets. Secure and stable communication ensures that the response of said troops is coordinated, safe and effective, reducing exposure to risks derived from climate change, reducing their impact and increasing resilience thanks to better post-impact management. At the same time, emergency teams need the signal provided by Cellnex to send early warning signals in the face of possible disasters, thus ensuring greater preparation of organizations and people, which increases their resilience to potential damage.
Based on the above, it is considered that this activity fits within the adaptation activity 8.3. Radio and television programming and broadcasting activities within Annex II of the Climate Delegate Act. In its definition it includes “… It also includes data broadcast, which is usually integrated with the radio or television broadcast. The broadcast can be made using different technologies: by airwaves, by satellite, by cable or by Internet…”. In the case of Mission Critical, data is broadcast via radio that facilitates adaptation.
In 2021, this activity was already incorporated into the Cellnex 2021 Taxonomy report and all interested parties considered it reasonable. It is considered that Mission Critical fits into the radio broadcast due to the fact that any communication from the emergency services must pass yes or yes through Cellnex towers, where this signal is received and emitted again so that it is transferred directly to the corresponding system, ensuring safe and efficient transmission.
Considering the section of the activity associated with facilitating activities, it is understood that Cellnex's interpretation is one of the only ones that could fit into the approach made because it uses the emission of radio waves as the means to facilitate an increase in resilience and adaptability to climate change.
Based on the technical clarification of the European Commission regarding the interpretation and implementation of the technical selection criteria and DNSH of the climate objectives of December 19, 2022, it is established that the facilitating activities have to (i) ensure that they are adapted to climate change, and (ii) contribute to the resilience or adaptation efforts of third parties.
Cellnex has carried out a Climate Change Adaptation Plan during 2022 that has two different parts, (i) a first focused on analyzing the climate risk of all its assets, and (ii) a second focused on proposing adaptation activities and proposals to those assets at risk. For the Mission Critical business, the percentage of assets adapted to climate change linked to the transmission of information has been valued, considering the rest as non-aligned.
The Final Report on Minimum Guarantees of the Platform in Sustainable Finance of October 2022 provides relevant information on how to interpret compliance with the criteria established in the reference frameworks presented above. There are overlapping issues in Article 18 and the different principles or recommendations set out in the UNGP and the OECD guidelines. The UNGPs play a general role in the application of the minimum guarantees. They define the responsibilities of private and public companies to ensure respect for human rights. The same is true of the OECD Guidelines for Multinational Enterprises.
Taking into account the above, the substantive and relevant issues that continue to be relevant for the minimum guarantees are the following, leaving the environment and science and technology as aspects of the responsibility of the states:
Based on the review of the procedures, policies and analysis on the subject of minimum guarantees, it is considered that Cellnex Telecom complies in all its activities and geographical areas with the minimum guarantees established in the framework of Regulation 2020/852/UE of Taxonomy. For each of the substantive issues presented above, the company has identified the documents, where it develops the measures and procedures for each issue and which are available to stakeholders on the corporate website.
Substantive issues |
Cellnex documents |
Fair competition |
Code of Ethics (point 3.3.3.7) |
Taxation |
Code of Ethics (point 3.3.3.4) Tax Policy, Tax Compliance Committee IAR pages 130-134 |
Human rights |
Code of Ethics (point 3.3.3.2) Politics Human rights Due Diligence Human Rights Equity Diversity and Inclusion Policy Supplier Code of Conduct |
Labor rights |
Collective agreements, OHS Policy, ISO 45001 Equity, Diversity and inclusion Policy Politics Human rights Harassment Prevention Protocol (ES) |
Interests (rights) of consumers (customers) |
Code of ethics (point 3.3.7.2) Global Quality Policy Customer satisfaction survey Information Security Policy |
Bribery |
Code of Ethics (point 3.3.6) Corruption Prevention disciplinary system Whistle blowing channel |
Transversal documents |
ESG Policy Disciplinary system (for all employees) Cellnex Annual Report |
As previously stated, the Taxonomy requires the reporting, in 2022, of the percentage of income, CapEx and OpEx eligible and aligned based on the economic activities published in the Climate Delegated Act, which covers both adaptation and mitigation to climate change.
The financial information used for this analysis was subject to an external audit when the annual accounts for the year were closed. These were subject to joint analysis and control by the local and central teams to ensure consistency with the consolidated revenue for the year. Controls focused on both the treatment of intragroup transactions and the breakdown of revenue by business segment and sub-segment.
The consolidation of financial data is governed by IFRS accounting policies and is audited by Cellnex's financial auditors. The financial data is extracted from the so-called "reporting package" of each country, whose data comes from the "FCCS" consolidation ERP system, which is fed by "PBCS" which in turn is fed by "SAP" or local ERP depending on each country. The computerization of these processes ensures the minimization of human errors.
The income presented here is recorded as follows by commercial activity:
It is necessary to emphasize the casuistry of Broadcast and Internet Media, both activities fit into activity 8.3 Radio and television programming and broadcasting activities of Annex II of Adaptation to Climate Change of Delegated Regulation 2021/2139/UE. Due to the type of activity, they are classified as activities adapted to climate change. For this type of activity, the Delegated Disclosure Regulation (Article 8) 2021/4987/UE, which defines in its Annex I the content to be published by non-financial companies, establishes that the income generated by adapted activities cannot be incorporated into the numerator of the % revenue aligned with the taxonomy. This means that, although Broadcast and Internet Media activities are aligned with the TSC and DNSH established in the Taxonomy Regulation, their income, due to the type of activity, cannot be counted in the income indicator.
Based on this, we could say that of the eligible activities, 8.76% of the eligible income corresponds to leases - Datacenter business - and the remaining 91.24% is based on contracts with clients for specific services.
The data reported in the report does not consider the production of companies for others within the Cellnex group. This case could occur in some activities, but data has only been reported at the consolidated level of income from external customers.
To avoid double counting, the calculations of the different indicators have differentiated between activities incorporated in the mitigation or adaptation objective, counting only based on the objective where the contribution is considered more substantial. In this way, duplicate accounting of the same item of income or CapEx is avoided.
At the level of economic activity:
Capex:
Based on operating income and Capex items linked to eligible and aligned activities, 2022 presents significant changes from 2021 in terms of:
Below are the eligibility and alignment results based on the tables in Annex II of the Delegated Act of Article 8. The disclosure of information in this format is required as of 2023, to disclose the results in a standardized manner by of economic agents and participants in the financial market.
The results obtained in this second year of evaluation of the degree of eligibility and first year of alignment of Cellnex activities, under the list of economic activities of the Taxonomy regulation, present levels similar to those of the last year. The Taxonomy does not incorporate the bulk of Cellnex's business. It is considered that Regulation 2020/852/EU of the European Union does not conform to a useful tool to assess the environmental sustainability of the group's business. This is so due to the fact that most of the economic activities that are carried out have not been included in the list of mitigation and adaptation activities. Consequently, Cellnex cannot assess whether or not it meets the technical selection criteria and thus assess its substantial contribution to sustainability. For those activities where it does meet the technical selection criteria, you cannot report said income as aligned due to a methodological consideration. The Delegated Disclosure Act (Art. 8) establishes that “adapted” activities cannot be counted in the numerator of the income indicator.
Of the total operating income, 8.27% are established as eligible based on the taxonomy. Of these eligibility percentages. we have that 13.60% of the eligible income is considered aligned. The eligible and aligned income indicator being 1.13% of total income. On the other hand, it is established that 1.15% of Capex is considered eligible, being 9.09% eligible and aligned based on the total eligible. and 0.10% eligible and aligned based on total Capex. The most important variation between eligibility and alignment in the income section comes from the methodological impossibility of accounting for Broadcast and Internet Media income in the numerator. although they are considered aligned.
Cellnex has adopted a conservative approach when reporting eligibility and alignment based on the Taxonomy, avoiding forcing the definitions of economic activities to incorporate activities of its business. It is understood that the regulation has the objective of avoiding "greenwashing" and it would not do any good to try to adjust the regulation in favour of the company. An approach that responds to the principles of integrity, representativeness and veracity has been maintained.
Internally, Cellnex has worked during 2022 to carry out the relevant evaluations and validations to ensure compliance with the criteria set out in article 3 of regulation 2020/852/UE. The technical selection criteria have been validated for each of the different business units that carry out the same Taxonomy activity, trying to obtain evidence or certificates that prove compliance with the criteria established at the most granular level possible. The same approach has been used to validate the criteria of Do Not Significant Harm (DNSH) to other environmental targets. Finally, the minimum guarantees have been validated at the group level due to the fact that they are internal procedures or policies applicable to all the company's subsidiaries.
Cellnex assumes as its purpose in the coming years, to improve the degree of alignment of the company to the technical selection criteria and DNSH principles of its eligible activities, to maintain those classified as aligned during 2022 and to improve the methodologies and procedures for the development of applicability and usability of the Taxonomy.
Below are the mandatory reporting tables for this year on the degree of eligibility and alignment of the company with Regulation 2020/852/UE.
Operating income
The most relevant income item for the group, Telecommunications Infrastructure Services (TIS), which represents approximately 67% of the group's income, could not be included in the eligibility and alignment calculations given that within the economic activities environmentally sustainable that the regulation presents, there is still no activity in line with that carried out by Cellnex. The TIS activity is based on the operational efficiency of telecommunications towers by sharing them among several operators, an activity with a positive environmental impact since it avoids the duplication of infrastructures, optimizes the occupied land, reduces the impact on biodiversity and achieves improvements in energy efficiency. The lack of development of the Taxonomy generates damage to the public image of the company, whose main business is linked to operational and energy efficiency.
At the same time, Cellnex has revenues linked to eligible and aligned economic activities that are higher than those provided in the indicator. Based on Annex II of the Climate Delegated Act (Climate Change Adaptation Activities) certain economic activities of the company meet the eligibility and alignment criteria, but are not counted in the alignment percentage numerator. Broadcast and Internet Media activities, in excess of 204 million euros in aligned revenue, could not be accounted for since they are classified as "adapted" activities under adaptation activity 8.3, Radio and television programming and broadcasting activities. At a methodological level, the Delegated Disclosure Act establishes that "adapted" activities are not considered sustainable, greatly affecting Cellnex's aligned revenue KPI. The alignment percentage would increase to 6.97% if Broadcast and Internet Media activities, considered as adapted, were included.
The European Parliament and the Council have prioritized the coverage in the regulation of economic activities that can make, from their point of view, the most relevant contribution to the two environmental objectives considered. This first Delegated Act focuses on climate objectives (mitigation of climate change and adaptation to climate change) and, therefore, includes the most relevant activities for reducing greenhouse gas emissions and for improving climate resilience. . This includes the sectors with the highest contribution to CO2 emissions (energy, manufacturing, transport, buildings), as well as the activities that enable their transformation or transition, necessary to achieve the EU climate objectives. This approach poses the paradox that the most polluting sectors such as energy or transport are covered by regulation, while the activities of the digital sector, which have less impact, are not. This is why the eligibility percentages of some companies, to be published in 2022, are going to be much higher than those of Cellnex due to the mere fact that their economic activity or sector is covered by regulation, while a large part of the Cellnex turnover (TIS), is not incorporated.
The number of economic activities of the ICT sector represented in the Climate Delegated Act only reaches 4 (Climate Change Mitigation) and 6 for repetitions of two activities that also includes the Adaptation delegated act, of more than 200 activities contemplated in the Taxonomy current. Some of them are too general or specific to be able to bring together a representative part of the companies in the sector.
These activities include:
Unfortunately, the bulk of Cellnex's business is not included in the lists of sustainable economic activities or is included as an adapted activity, a categorization that does not allow them to be counted in the Taxonomy indicators.
The CapEx items considered in the calculation represent (i) those investments in eligible economic activities and aligned based on the Taxonomy - especially Datacenters, IoT Smart Services, Mission Critical - and (ii) activities mentioned in category (c) of the section 1.1.2.2 of Annex I of the Delegated Disclosure Act, related to the purchase of products and individual measures of eligible economic activities or energy efficiency measures. The items incorporated in point (ii) are especially investments in renewable energy equipment and energy efficiency improvements. As with the income section, Cellnex cannot account for investments associated with "adapted" economic activities. This is the case of investments linked to Broadcast and Internet Media. In the same way, the investment items in activities linked to the operational and energy efficiency of telecommunications towers, such as TIS, could not be accounted for since the activities are not considered eligible.
Cellnex has recently published a Sustainability-linked Financing Framework, which has obtained a second-party opinion from specialists, stating that it complies with international financial sustainability criteria. The framework or plan has the objective of issuing sustainable bonds or obtaining sustainable loans, while complying with strict objectives of decarbonization, use of renewable energy and equality between men and women. However, many of the investments in sustainability cannot yet be counted as eligible since the company does not have a specific Investment Plan linked to the improvement of the KPIs of the Taxonomy.
Cellnex has decided not to calculate the OpEx KPI as it is not considered material for the group's business. The company considers that the OPEX margin for the calculation of the Taxonomy is not material, mainly and in accordance with IFRS16 accounting regulations, the most significant item (rental costs) is reflected in financial interests and in the amortization of the financial statements. of the company. Therefore, it causes the company to have very high operating leverage and margin.
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