CELLNEX TELECOM S.A. Report on the Corporate Responsability Policy at Cellnex Telecom

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1 CELLNEX TELECOM S.A. Report on the Corporate Responsability Policy at Cellnex Telecom February 17th 2016

2 Notice on the Corporate Responsibility Policy at Cellnex Telecom Cellnex Telecom is a neutral, independent telecommunications infrastructure operator with an international ambition and scope. In accordance with the principles laid down in its bylaws and its code of good governance, the company operates in a transparent and accountable manner with its stakeholders and its surrounding environment. Cellnex aims to maximise the benefits to society, providing access to the technologies of a digital economy and a society marked by the impact of connectivity and permanent access, and enabling mobility services and applications for businesses, institutions and the public. Likewise, Cellnex's management seeks to achieve these goals by using a responsible and sustainable management of the infrastructures that facilitate this connectivity in terms of economic efficiency and social and environmental balance, with all that these elements can contribute to creating value models that are close to what is known as the circular economy was a challenge for Cellnex, from various perspectives, including defining and laying the foundations of its Corporate Responsibility policy by developing a corporate responsibility master plan. The purchase of a package of 7,400 telecommunication sites in Italy from the Telecommunications operator WIND in March 2015 in an operation that has positioned the company as a strategic player in the sector in that country, the renaming on 1 April 2015 of what was Abertis Telecom Terrestre, which henceforth operated under the name Cellnex Telecom, and the subsequent segregation of the Abertis group after placing 66% of the company on the stock exchange on 7 May, show clearly just how deeply transformational this year was. The combination of all these factors highlighted the need and the importance of endowing the company with a set of policies, which includes Corporate Responsibility, to ensure that Cellnex Telecom fully complies with its obligations as a listed company in terms of transparency and responsible management of the business. In order to make Corporate Responsibility a natural element of the company and to place it at the highest level of corporate governance, the Board's Appointments and Remuneration Page 1 of 6

3 Committee took on the role of supervising this policy, firstly to define it and then to develop and roll it out. Among the measures that established the preconditions for developing the Corporate Responsibility policy, we could point to the adoption of the new Cellnex Code of Ethics, which applies to all employees and aims to create a standard of conduct for the entire company. This Code also regulates the Ethical Channel, which serves both for making inquiries and sending notifications of any conduct that breaches the Code or any internal rule of behaviour. The company's risk map was also updated, from all points of view of the business, and a specific project launched to implement a system for detecting and preventing criminal risks was also an important year from the perspective of the framework into which Cellnex CR policy fits, since it was then that the company signed up to the United Nations Global Compact as one of the pillars of its corporate responsibility policy. The Global Compact expresses the commitment to promote and spread corporate sustainability policies and practices based on the ten key principles promoted by the United Nations, focusing on the areas of human rights, labour standards, environment and anti-corruption in the business activities of companies. Maintaining and developing processes and capabilities to uphold the confidence of its customers, employees and other key organisations for the performance of its activities at all levels links up to initiatives already pushed forward within the Abertis Group. At the time, these made it possible to implement a series of procedures, checks and best practices, which Cellnex Telecom has continued, to maintain high standards of sustainable business management. Specific examples of this are the ISO 14001, ISO 9001, OHSAS 18001, UNE and ISO27001 certifications that make up the Integrated Management System implemented in Cellnex; as well as the BEQUAL label, which certifies the company as socially responsible towards persons with disabilities. Moreover, a key factor for the future of Cellnex is the company's internationalisation drive, setting it up as a European benchmark in telecommunications infrastructures management. This represents a significant challenge when spreading accountability and extending the same Page 2 of 6

4 guiding principles to all the newly incorporated companies, such as TowerCo and Galata in Italy, and any that may be integrated in the future. Corporate Responsibility Master Plan To articulate all of the challenges related to corporate responsibility and respond to the commitments of stakeholders in the coming years, the company implemented a process to define Cellnex's CR Master Plan adapted to its objectives and interaction with its stakeholders. With this Master Plan, Cellnex aims to create an instrument that brings together all the company's ethical, environmental and social initiatives, with a long-term vision; establishing a series of commitments in accordance with internationally recognised standards that place it on the same level as the major infrastructure companies operating in Europe, specifically in the telecommunications sector. The process of defining the CR Master Plan The process of drawing up the CR Master Plan involved a number of tasks that helped Cellnex Telecom to acquire a better understanding both of the expectations of its surroundings and of the activities taking place within the competitive environment. This approach started with a diagnosis of Cellnex's initial situation with regard to Corporate Responsibility based on an analysis of the expectations and priorities of its stakeholders. The analysis of the internal perspective was created after studying the company's plans and integrated management systems. Similarly, senior management was consulted about its vision, interests and ambitions in relation to CR at Cellnex, and key aspects along the company's value chain were identified. Furthermore, to find out more about the external perspective, the company performed an exercise to identify and map Cellnex stakeholders. It also analysed the trends in public information within the telecommunications sector and performed a benchmarking study to evaluate Cellnex's positioning with regard to the competition and to learn about CR best Page 3 of 6

5 practices within the sector. To understand in greater detail the perception and expectations within the telecommunications sector and, specifically concerning Cellnex, it held interviews with stakeholders from various groups considered as relevant according to the mapping exercise (academia, public customers, private customers and associations) and was able to establish the viewpoint of most of them. As a result of this analysis of the expectations of both internal and external agents, Cellnex was able to prioritise CR issues according to their importance within the company, to define the strategic lines that guide the CR Master Plan, using two materiality matrices of various aspects of CR on the basis of the information from the previous phase. The issues considered material for Cellnex Telecom are thus: 1. Corporate governance. 2. Ethics, governance and compliance (policies and initiatives). 3. Engagement with stakeholders. 4. Transparency and reporting. 5. Risks and opportunities management (business, environmental, societal, etc.). 6. Energy. 7. Responsible recruitment of employees / involvement and commitment of workers. 8. Capacity building, professional development and talent retention. 9. Management of socio-economic impacts on local communities. 10. Responsible procurement. On the basis of these issues, which are material for the responsible management of the company, the company identified a number of areas of action: 1. Ethics and corporate governance. 2. Development of people. 3. Sustainable business development. 4. Valuable contribution to society. 5. Communication and reporting. Page 4 of 6

6 6. CR governance. These areas were then used to define lines of action and propose actions to be developed and driven by Cellnex within the field of CR, with a total of 23 lines of action and 98 actions ultimately defined. These actions, each one in the corresponding area, were performed in such a way that they will ensure the development of responsible management of the company, integrating the various functional and business areas to mainstream implementation of the initiatives defined in the Plan. The Cellnex integrated report From the point of view of information reporting, Cellnex Telecom has opted to gradually adopt the integrated reporting model, following the guidelines of the International Integrated Reporting Council (IIRC), within which it will also report non-financial information such as the environmental and social impacts that the company generates on its surroundings. A sufficient scope for this reporting was defined on the basis of a materiality analysis, which helps to identify the priorities and expectations of key stakeholders as regards information and to respond to these in the form of a report. Once the issues to be reported were defined, an analysis was made of how to respond to these information requirements using standard indicators from the GRI (Global Reporting Initiative) G4 Guide. Dissemination and monitoring of compliance with the Corporate Responsibility policy As already indicated, the Company will incorporate information on the progress and compliance in each of the areas identified in its Integrated Annual Report. It falls to the Board's Appointments and Remuneration Committee, which answers to the Board of Directors itself, to conduct periodic monitoring of both the content and the application and development of the Corporate Responsibility Policy. Page 5 of 6

7 CR policy coordination is performed by the Public and Corporate Affairs Department. Page 6 of 6