Environmental, social and governance policy
(ESG Policy)

1. Introduction and Objectives

We believe technology can link countries, unite cities, connect businesses and bring people together. We aim to roll out networks that connect us to tomorrow, powering, facilitating and securing business communications.

At lyntia Networks, we are firmly committed to ESG principles, consolidating our vision of transforming tomorrow. This commitment focuses on technological development and maintaining territorial cohesion, improving social well-being and driving a competitive economy. lyntia Networks embraces its corporate responsibility, adopting practices that optimise financial performance and contribute significantly to social and environmental progress.

This ESG policy sets out the basic principles and actions that demonstrate lyntia’s commitment to ethical and environmentally-responsible business, social issues and good governance

2. Our Principles

The principles of integrity, neutrality, risk management and accountability guide our actions. We have a responsibility to build a fair and secure digital environment. This environment must enable social development while respecting the environment.

Integrity

Integrity is essential to the success of our business. All employees, executives and suppliers interested in working with lyntia must adhere to and comply with our Code of Ethics

Neutrality

lyntia is a neutral operator that provides wholesale services to national and international operators, hyperscalers and utilities. We believe in network neutrality as a basic cornerstone to build a connected business and bring people together, avoiding conflicts of interest and ensuring good governance.

Risk Management and Responsibility

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

3. Our Actions & Commitment

To materialise our ESG vision, we have established a strategic Working Group covering all areas of the company: Human Resources, Communication, Legal, Finance, Procurement, Technology, Sales and Marketing. This team, rigorously supervised by the Executive Committee and the Board of Directors, is responsible for developing and implementing the ESG plan, assuming sustainable development and the well-being of people as the key to the success of lyntia’s business project, contributing to the achievement of the social interest.

We have defined the basis of our commitment – through internal and external analysis – to identify and prioritise the most relevant aspects for our organisation. From these analyses, we have identified the most important and impactful ESG initiatives. In addition, we are committed to regularly reviewing our materiality matrix to reflect the dynamism of society and key stakeholders.

1.1. Environmental Aspects

We are aware that we rely on material resources to run our business. As part of society, we commit ourselves to work actively to make efficient use of these resources.

We are committed to and work towards:

• • • Respecting applicable environmental regulations and ensuring compliance with environmental requirements where the company operates.
  • • Contributing to a model of implementing activities that consider the life cycle of infrastructures, facilities and buildings, always prioritising and minimising the environmental impact.
  • • Analysing our impact on climate change and developing measures to reduce our carbon footprint.
  • • Monitoring energy consumption and ensuring that this is optimised at our facilities and that energy consumption associated with non-renewable energy sources is reduced.
  • • Incorporating environmental criteria and considering environmental risks in investment and procurement decision-making processes and in the planning and implementation of activities.
  • • Promoting a culture of environmental protection among employees.
  • • Promoting visibility and transparency regarding information reported on lyntia Networks’ environmental performance results.
  • • Education and awareness: Promoting awareness among employees of the importance of water and how to contribute to its conservation.

1.1.1. Sustainable mobility

We aim to reduce the environmental impact of corporate travel. We seek to optimise the use of sustainable vehicles and encourage sustainable practices among employees based on two principles:

• • Reducing emissions: lyntia is committed to reducing the carbon footprint of corporate travel by promoting the use of hybrid or electric vehicles for its internal fleet. The company aims to transform its internal vehicle fleet to an all-electric model by 2050. We also reduce our employees’ travel emissions by promoting a hybrid working model, with two teleworking days per week.
  • Agreements with third parties: We encourage the search for agreements with service companies that offer sustainable mobility solutions to reduce our Scope 3 emissions footprint, optimise our resources, and provide tax benefits to employees.

1.1.2. Biodiversity

At lyntia, we integrate biodiversity conservation into all our telecommunications infrastructure rollout and operation activities, ensuring that our actions minimise environmental impact and promote the protection of the natural environment. We are committed to a sustainable growth approach, supporting the conservation of ecosystems and biodiversity in the areas in which we operate.   We are committed to and work for:

• • Regulatory compliance: We will comply with all applicable environmental legislation and align with international best practices on biodiversity.
  • Prevent and mitigate our environmental impact: We will apply the mitigation hierarchy (avoid, minimise, restore and compensate) in all phases of our projects.
  • Rigorous analysis and traceability: We will identify and assess potential impacts on biodiversity prior to the start of any project in non-urban areas. We are committed to rigorous monitoring of activities that may affect biodiversity, ensuring traceability, and reporting environmental impacts.
  • Protection of vulnerable ecosystems: We will avoid using infrastructure in areas of special environmental sensitivity or high ecological value wherever possible.

1.1.3. Sustainable management of resources

We aim to reduce our impact on water, particularly in areas of high water stress, by promoting a conscious and efficient use of this resource in our fibre-optic rollout facilities and operations. We aim to contribute to preserving this essential resource in the context of the increasing risk of drought. We are committed to working with our partner companies to ensure the responsible use of water resources. We strive to raise awareness among lyntia employees about saving water at our facilities through internal communication campaigns. We also collaborate with the lessor of our offices to ensure proper traceability of our consumption.

1.2. Social Aspects

1.2.1. Employees

Our employees are essential for creating a positive impact and generating value as an engaged organisation. We are committed to and work to:

• • • Ensure that current legislation on working conditions is respected and adequately enforced, focusing on the principles in the UN Universal Declaration of Human Rights.
  • • Promote diversity, equality and inclusion to create value for the organisation.
  • • Actively assist employees to continue their professional development within the organisation through various training programmes.
  • • Promote measures to reconcile work and family life (work-life balance).
  • • Promote measures to protect the health, safety and well-being of the people we work with.

1.2.2. Customers

• • • Our customer satisfaction policy is designed to ensure comprehensive end-to-end operational control and enhance the customer experience. Throughout the entire customer lifecycle, including sales, delivery, service delivery, billing and NOC phases, we assign a specific manager for each stage, ensuring efficient and coordinated management.
  • • We use the NPS to assess customer satisfaction at every stage and identify opportunities for improvement. Based on the results of the surveys, we implement specific action plans to strengthen our customer engagement and improve the quality of the service we provide.
  • • We establish clear and accessible contact channels, both by email and telephone, to handle any urgent matter quickly and efficiently.
  • • We are committed to constant accompaniment, ensuring that customers receive the necessary support in all areas and stages. This allows us to identify their needs, resolve their concerns and strengthen a lasting and positive relationship.
  • • In this way, we seek to continually improve the customer experience, ensuring customer satisfaction and loyalty throughout their interaction with lyntia.

1.2.3. Suppliers and supply 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.

• • • Encourage our suppliers to align themselves with our organisation’s sustainability principles and adhere to the guidelines of this policy and any other relevant internal regulations.
  • • Safeguard and improve the environment throughout our supply chain, encouraging the efficient and conscientious use of resources, emphasising operational efficiency and reducing the environmental impact.
  • • Our supply chain is key to maintaining and developing our business. We are committed to and work to integrate relevant ESG criteria into our supply chain.

1.2.4. Local employment

We promote employment opportunities in the communities where we operate, prioritising the hiring of local talent and ensuring fair and inclusive practices. We offer training programmes to improve skills and foster a diverse environment that strengthens relationships with communities, drives regional economic development and ensures a team committed to business success and sustainability. Our policy covers all of the company’s recruitment practices and employment initiatives, prioritising the recruitment of the local workforce to support employment in the community. We foster an inclusive work environment that promotes diversity and inclusion, creating a supportive environment for all employees. In this way, we strengthen our relationship with local communities, improve the quality of employment and ensure a committed and skilled workforce that contributes to the success of our business and the sustainable development of the regions where we operate.

1.2.5. Policy on Social Enterprise Partnership

Our commitment to social and environmental responsibility is based on creating strategic partnerships with social enterprises, non-profit organisations and other entities. Through these partnerships, we seek to implement meaningful actions that generate lasting and positive impacts on society and the environment. The procedure to be followed for the selection of the organisations and projects with which we collaborate is as follows:

• 1. Identification of needs: We identify and prioritise areas where our actions can make a significant difference, guided by sustainability, inclusion and solidarity values.
  2. Partner selection: We collaborate with organisations that share our values and impact vision, ensuring the alignment of aims and a genuine commitment to social and environmental change.
  3. Project development and implementation: We design initiatives that respond to identified needs, implementing organised and sustainable actions that guarantee a long-term impact.
  4. Monitoring and transparency: We evaluate the progress and results of each partnership, emphasising transparency and accountability.

1.3. Governance Aspects

1.3.1. Data and network security

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

• • • Respecting privacy and implementing measures to ensure the security of personal data. Our privacy policy ensures compliance with the General Data Protection Regulation.
  • • Developing a robust cyber security programme.
  • • Complying with the principles of network neutrality.

1.3.2. Corporate Governance

• • • Governance structure: We are committed to creating a transparent governance structure that fosters mutual trust with stakeholders.
  • • Ethics and transparency: The ethical principles developed in the Code of Ethics constitute the cornerstones on which lyntia’s activity is based. We have a responsibility to act ethically and transparently, aligning ourselves with regulatory requirements.
  • • Compliance and whistleblowing channel: We constantly reinforce our Internal Reporting Channel in accordance with applicable regulations, Directive (EU) 2019/1937 and Law 2/2023.
  • • Compliance with regulations and legislation in force: Compliance with the law, implementing commitments and regulations voluntarily and in good faith.
  • • Investor relations: The main principles of investor relations with the Board of Directors include loyalty, good faith and transparency, prioritising the social interest over individual interests, the responsible exercise of rights with equal treatment, and facilitating the informed participation of investors, in accordance with the law and corporate governance rules.

1.3.3. Relations with stakeholders

Our stakeholder relations policy is designed to manage and foster positive relationships with all groups and individuals affected by our operations, including employees, customers, suppliers, investors and the wider community.

We are committed to transparent communication through open and honest channels, ensuring that the interests of all parties are considered in our business decisions. We implement active engagement strategies that involve stakeholders in decision-making processes, enabling effective collaboration and a better understanding of their needs and expectations.

We have assigned managers for each stakeholder to ensure a rapid and effective response to any concerns or feedback received.

We foster trust-building through consistent and ethical business practices, promoting an inclusive environment where all voices are heard and represented in our initiatives.

In addition, we establish action plans based on the results of periodic surveys and evaluations to continuously improve our relationships and strengthen our commitment to quality and social responsibility. In this way, we ensure the comprehensive and controlled management of our stakeholder relations, always seeking to improve the experience and satisfaction of all those involved and contribute to the sustainable success of our company.

1.3.4. Independence of the Chairman of the Board

Our policy of independence of the Chairman of the Board is designed to maintain impartiality and objectivity in our organisation’s leadership and governance. This policy applies to the Chairman of the Board’s role and responsibilities, ensuring that his position remains independent from executive management. To achieve this, we ensure the separation of roles, guaranteeing that the Chairman of the Board does not perform executive management functions.

In addition, we prevent conflicts of interest by requiring the Chairman of the Board to disclose any potential conflicts that could affect his impartiality. We empower the Chairman of the Board to make decisions objectively, free from undue influence from internal or external parties, thereby promoting fair and balanced governance. We implement limits on the Chairman’s mandate to encourage the incorporation of new perspectives and reduce potential bias, ensuring constant leadership renewal.

We also regularly evaluate the performance and independence of the Chairman of the Board, ensuring that standards of impartiality and effectiveness in leadership are maintained.

Through these guidelines, we seek to ensure strong leadership and transparent governance that contribute to our organisation’s success and sustainability.

4. Revision

We are determined to meet these voluntary commitments and, therefore, have according mechanisms in place to ensure their implementation. The ESG Working Group reports to the Management Committee on ESG progress monthly to ensure compliance and implementation of agreed actions. In addition, lyntia’s ESG managers report to the Board of Directors and its ESG experts on a recurring basis on all relevant ESG indicators to report and inform any progress on our ambition in this regard.

Versions & Approval

This policy was approved by lyntia Networks’ administrators on the 7th January 2025

Version: 2.0