Environmental, social and governance policy
(ESG Policy)

1. Introduction & Objectives

We believe that technology enables connecting countries, uniting cities, linking businesses, and bringing people closer. Our goal is to deploy networks that connect us to the future, driving, facilitating, and protecting business communications through fiber optic networks, satellite services, and co-location services in Spain.

At Lyntia Networks, we are firmly committed to the principles of ESG, consolidating our vision of transforming the future. This commitment focuses not only on technological advancement but also on maintaining territorial cohesion, improving social well-being, and promoting a competitive economy. Lyntia Networks embraces its corporate responsibility by adopting practices that not only optimize financial performance but also contribute significantly to social and environmental progress.

This ESG policy outlines the fundamental principles and actions that demonstrate Lyntia’s commitment to developing an ethical and responsible business concerning environmental, social, and governance aspects.

2. Our Principles

Integrity

Integrity is essential for the success of our business. All employees, executives, and stakeholders interested in working with Lyntia must adhere to and comply with our Ethical Code.

Neutrality

Lyntia is a neutral operator that provides wholesale services to operators and utilities. We believe in network neutrality as a fundamental pillar for building a connected business and bringing people together, avoiding conflicts of interest, and ensuring good governance.

Risk Management and Responsibility

Proactivity, transparency, and risk management are our ways of demonstrating responsibility.

3. Our Actions & Commitment

To materialize our ESG vision, we have established a strategic Working Group that encompasses all areas of the company: Human Resources, Communication, Legal, Financial, Procurement, Technology, Commercial, and Marketing. This team, rigorously supervised by the Executive Committee and the Board of Shareholders, is responsible for developing and executing the ESG plan, considering sustainable development and the well-being of people as key to Lyntia’s business success.

We have defined the foundations of our commitment through internal and external analyses to identify and prioritize the most relevant aspects for our organization. From these analyses, we have identified the most significant initiatives with a substantial impact on ESG matters. Additionally, we are committed to regularly reviewing our materiality matrix to reflect the dynamism of society and its key players.

Environment

We are aware that we depend on material resources to conduct our business activities. As part of society, we commit to actively working to use these resources efficiently. We commit to:

• • • Adhering to environmental regulations applicable to the company’s operations.
  • • Contributing to an activity execution model considering the life cycle of infrastructures, facilities, and buildings, prioritizing minimizing environmental impact.
  • • Analyzing our impact on climate change and developing measures to reduce our carbon footprint.
  • • Monitoring energy consumption and ensuring optimization of facility energy consumption and a decrease in energy consumption associated with non-renewable energy sources.
  • • Incorporating environmental criteria and considering environmental risks in decision-making processes regarding investments and acquisitions, as well as in the planning and execution of activities.
  • • Promoting among employees a culture of environmental protection.
  • • Enhancing visibility and transparency regarding the information communicated about Lyntia Networks’ environmental performance.
  • • Education and Awareness: Fostering awareness among employees about the importance of water and how to contribute to its conservation.

Social

Employees

Our workers are essential to creating a positive impact and generating value as a committed organization. We commit to and work on:

• • • Ensuring compliance with current labor conditions, focusing on the principles outlined in the Universal Declaration of Human Rights by the UN.
  • • Promoting diversity, equality, and inclusion to create value for the entire organization.
  • • Actively assisting employees in continuing their professional development within the organization through various training programs.
  • • Promoting measures in favor of work-life balance.
  • • Promoting measures to protect the health, safety, and well-being of the people we work with.

Value Chain

Our value chain is crucial to maintaining and developing our business activities. We commit to and work on integrating relevant ESG criteria into our supply chain.

Clients

• • • Ensuring excellence in service by continuously monitoring customer experience through surveys and other methods that facilitate constant and effective feedback.
  • • Maintaining the strictest confidentiality in handling personal data of all our users.
  • • Addressing and efficiently resolving any complaints with the goal of achieving the highest levels of customer satisfaction.

Suppliers

• • • Encouraging our suppliers to align with the sustainability principles of our organization and adhere to the guidelines of this Policy, as well as any other relevant internal regulations.
  • • Safeguarding and improving the environment throughout our supply chain by encouraging efficient and conscious use of resources, with an emphasis on operational effectiveness and reducing environmental impacts.

Corporate Governance

Network & Data Security

Data privacy, good governance, and network neutrality are the most relevant aspects of this category. We commit to and work on:

• • • Respecting privacy and implementing measures to ensure the security of personal data, complying with the General Data Protection Regulation.
  • • Developing a robust cybersecurity program.
  • • Adhering to the principles of Network Neutrality.

Corporate Governance

• • • Governance Structure: We commit to creating a transparent governance structure that fosters mutual trust with Stakeholder Groups.
  • • Ethics and Transparency: The ethical principles outlined in the Ethical Code form the foundation of Lyntia’s activities. We have the responsibility to act ethically and transparently, aligning with regulatory requirements.
  • • Compliance & Whistleblower Channel: Constant reinforcement of our Internal Information Channel in line with applicable regulations, Directive (EU) 2019/1937, and Law 2/2023.
  • • Compliance with Regulations & Current Legislation: Compliance with legality, implementing commitments and regulations voluntarily and in good faith.
  • • Investor Relations: Fundamental principles in the relationship with the Board of Directors include loyalty, good faith, and transparency, prioritizing social interest over individual interest, exercising rights responsibly with equal treatment, and facilitating informed investor participation, in accordance with laws and corporate governance standards.

4. Revision

We are determined to fulfill these voluntary commitments and, therefore, have mechanisms in place to ensure their development. The ESG Working Group reports to the Management Committee monthly on progress in ESG matters to ensure compliance and implementation of agreed-upon actions. Additionally, Lyntia’s ESG responsible personnel regularly inform the Board of Directors and its ESG experts of all relevant indicators in ESG matters to report and inform about any progress in our ambition.

Versions & Approvals

This policy has been approved by the administrators of Lyntia Networks on January 29, 2024.

Version: 1.0