{"id":13976,"date":"2021-02-26T16:01:34","date_gmt":"2021-02-26T14:01:34","guid":{"rendered":"http:\/\/35.180.166.16\/?page_id=13976"},"modified":"2025-10-24T08:53:25","modified_gmt":"2025-10-24T07:53:25","slug":"environmental-policy","status":"publish","type":"page","link":"https:\/\/www.lyntia.com\/en\/environmental-policy\/","title":{"rendered":"Environmental, social and governance policy"},"content":{"rendered":"

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Environmental, social and governance policy
\n(ESG Policy)<\/span><\/h2>\n

 <\/p>\n

1. Introduction and Objectives<\/span><\/h3>\n

 <\/p>\n

We believe that technology connects countries, unites cities, links businesses, and brings people closer together. Our goal is to deploy networks that connect us to the future, driving, enabling, and securing business communications through fibre optic networks, satellite services, and colocation in Spain.<\/p>\n

At Lyntia Networks, we are firmly committed to ESG principles, aligning with our vision to transform tomorrow. We are guided by internationally recognized standards such as the Ten Principles of the United Nations Global Compact (UNGC) and the OECD Guidelines for Multinational Enterprises. This commitment goes beyond technological progress\u2014it encompasses territorial cohesion, social well-being, and the promotion of a competitive economy. Lyntia Networks embraces its corporate responsibility by adopting practices that not only optimize financial performance but also contribute meaningfully to social and environmental progress.<\/p>\n

This ESG policy outlines the basic principles and actions that demonstrate Lyntia\u2019s commitment to ethical and responsible business practices across environmental, social, and governance dimensions.<\/p>\n

 <\/p>\n

2. Our Principles<\/span><\/h3>\n

 <\/p>\n

The principles of integrity, neutrality, risk management, and accountability guide our actions. We are responsible for building a fair and secure digital environment that supports social development while respecting the environment.<\/p>\n

\u2022 Integrity: Integrity is essential to our business success. All employees, executives, and suppliers working with Lyntia must adhere to and comply with our Code of Ethics.<\/p>\n

\u2022 Neutrality: Lyntia is a neutral operator providing wholesale services to telecom operators and utilities. We believe in network neutrality as a fundamental pillar for building a connected business, avoiding conflicts of interest, and ensuring good governance.<\/p>\n

\u2022 Risk Management and Accountability: Proactivity, transparency, and risk management are how we demonstrate accountability.<\/p>\n

 <\/p>\n

3. Our Actions and Commitment<\/span><\/h3>\n

 <\/p>\n

To implement our ESG vision, we have created a strategic Working Group that spans all areas of the company: Human Resources, Communications, Legal, Finance, Procurement, Technology, Commercial, and Marketing. This team, overseen by the Executive Committee and the Shareholders\u2019 Board, is responsible for developing and executing the ESG plan, identifying sustainable development and human well-being as key factors for business success and social interest.<\/p>\n

We defined our commitments based on internal and external analyses to identify and prioritize the most relevant ESG issues. We regularly review our materiality matrix to reflect the changing priorities of society and its stakeholders.<\/p>\n

 <\/p>\n

Environment<\/strong><\/p>\n

We recognize our dependence on material resources for business operations. As part of society, we actively work to use these resources efficiently. We take a preventive approach to environmental challenges and strive to reduce the impact of our activities. We are committed to:<\/p>\n

\u2022 Complying with applicable environmental laws and ensuring compliance in all operational areas. We are working to implement an ISO 14001 environmental management system.<\/p>\n

\u2022 Setting measurable environmental objectives and integrating them into strategic planning. We publish environmental performance indicators as part of our ESG report.<\/p>\n

\u2022 Adopting a lifecycle approach for infrastructure, facilities, and buildings to minimize environmental impact.<\/p>\n

\u2022 Assessing our climate impact and implementing measures to reduce our carbon footprint, including a Net Zero commitment strategy and a decarbonisation plan.<\/p>\n

\u2022 Monitoring energy consumption and optimizing the use of energy in our facilities, aiming to reduce non-renewable energy use.<\/p>\n

\u2022 Incorporating environmental criteria and risks into investment and acquisition decisions and in planning and execution of activities.<\/p>\n

\u2022 Promoting an environmental protection culture among employees.<\/p>\n

\u2022 Ensuring transparency in communicating Lyntia Networks’ environmental performance.<\/p>\n

\u2022 Raising employee awareness about water conservation.<\/p>\n

\u2022 Sustainable mobility: Our goal is to employ a sustainable vehicle fleet (hybrid\/low emission) and transition to a fully electric fleet by 2050.<\/p>\n

\u2022 Biodiversity: We avoid construction in protected areas and conduct environmental impact studies before rural deployments. We also carry out reforestation and habitat restoration projects.<\/p>\n

\u2022 Sustainable water management: We aim to minimize water impact, especially in high-stress areas, by promoting efficient water use in fibre deployment operations.<\/p>\n

 <\/p>\n

Social<\/strong><\/p>\n

At Lyntia, we respect and promote internationally recognized human rights, as outlined in the Universal Declaration of Human Rights. We reject any form of complicity in human rights violations and maintain internal mechanisms for reporting and ethically resolving conflicts.<\/p>\n

 <\/p>\n

Employees<\/strong><\/p>\n

Our employees are essential to creating a positive impact and generating value as a committed organization. We are committed to and work to:<\/p>\n

\u2022 Ensure full compliance with current labour regulations, focusing on the principles set in the UN Universal Declaration of Human Rights.<\/p>\n

\u2022 Promote diversity, equality, and inclusion to create value across the organization.<\/p>\n

\u2022 Actively support professional development through various training programs.<\/p>\n

\u2022 Promote work-life balance measures.<\/p>\n

\u2022 Implement measures to protect health, safety, and well-being of our workforce. We are working to implement an ISO 45001 environmental management system<\/p>\n

\u2022 Support freedom of association and the right to collective bargaining.<\/p>\n

\u2022 Prohibit child labour, forced or compulsory labour, and any form of labour exploitation within our operations and those of our suppliers.<\/p>\n

 <\/p>\n

Supply chain<\/strong><\/p>\n

Our supply chain is key to our business development. We commit to integrating relevant ESG criteria into our supply chain and fostering collaborative relationships that promote responsible practices across our value chain.<\/p>\n

 <\/p>\n

Suppliers<\/strong><\/p>\n

\u2022 Encourage suppliers to align with our sustainability principles and adhere to this Policy and other relevant internal regulations.<\/p>\n

\u2022 Protect and enhance the environment throughout our supply chain, promoting efficient and conscious resource use, with a focus on operational efficiency and environmental impact reduction.<\/p>\n

 <\/p>\n

Clients<\/strong><\/p>\n

\u2022 Ensure service excellence by continuously monitoring customer experience through surveys and other feedback methods.<\/p>\n

\u2022 Maintain strict confidentiality in handling users\u2019 personal data.<\/p>\n

\u2022 Efficiently address and resolve complaints to achieve high customer satisfaction.<\/p>\n

\u2022 Monitor customer satisfaction, which is crucial to Lyntia\u2019s success. We apply a comprehensive management policy across the customer lifecycle, from sales to technical support.<\/p>\n

\u2022 Use NPS (Net Promoter Score) to evaluate satisfaction and implement improvements based on results, while providing accessible communication channels.<\/p>\n

 <\/p>\n

Local Employment<\/strong><\/p>\n

Promote employment opportunities in the communities where we operate by prioritizing local talent, ensuring fair and inclusive practices. We offer training programs to enhance skills and foster a diverse environment that strengthens community ties, drives regional economic development, and supports our business success and sustainability.<\/p>\n

 <\/p>\n

Social Enterprise Partnership Policy<\/strong><\/p>\n

We are committed to social and environmental responsibility and seek to establish strategic partnerships with nonprofit organizations. Each year, we select impactful local projects to support causes such as reforestation, job inclusion, or access to education.<\/p>\n

 <\/p>\n

Governance<\/strong><\/p>\n

Data and Network Security<\/p>\n

Data privacy, good governance, and net neutrality are the most relevant aspects of this category. We are committed to and work to:<\/p>\n

\u2022 Respect privacy and implement measures to ensure the security of personal data. We<\/p>\n

have a privacy policy that complies with the General Data Protection Regulation (GDPR).<\/p>\n

\u2022 Develop a robust cybersecurity program.<\/p>\n

\u2022 Adhere to network neutrality principles.<\/p>\n

\u2022 We work to protect the integrity and security of the network and our data, adhering to the highest international standards such as the National Security Framework and ISO 27001.<\/p>\n

 <\/p>\n

Corporate Governance<\/strong><\/p>\n

\u2022 Establish a transparent governance structure to foster mutual trust with stakeholders.<\/p>\n

\u2022 Uphold ethical principles outlined in the Code of Ethics as the foundation of Lyntia\u2019s operations.<\/p>\n

\u2022 Act ethically and transparently, complying with regulations.<\/p>\n

\u2022 Report our sustainability progress through annual reports aligned with international standards such as GRI and TCFD.<\/p>\n

\u2022 Engage stakeholders (customers, employees, communities, regulators) to integrate their expectations into our ESG strategy.<\/p>\n

\u2022 Continuously strengthen our Internal Reporting Channel in line with Directive (EU) 2019\/1937 and Law 2\/2023.<\/p>\n

\u2022 Comply with all applicable laws and regulations, and voluntarily implement internal commitments.<\/p>\n

\u2022 Lyntia is committed to responsible tax practices, ensuring full compliance with applicable tax laws and promoting transparency, fairness, and integrity in all fiscal matter<\/p>\n

\u2022 Foster loyal, transparent, and informed relationships with the Board of Directors and investors, prioritizing social interest over individual interest.<\/p>\n

 <\/p>\n

Stakeholder Relations<\/strong><\/p>\n

Our stakeholder engagement policy is designed to manage and promote positive relationships with all groups affected by our operations, including employees, customers, suppliers, investors, and the broader community.<\/p>\n

\u2022 Maintain transparent communication through open and honest channels, ensuring stakeholder interests are considered in business decisions.<\/p>\n

\u2022 Implement active participation strategies to involve stakeholders in decision-making processes.<\/p>\n

\u2022 Assign dedicated representatives for each stakeholder group to ensure quick and effective response to concerns and feedback.<\/p>\n

\u2022 Build trust through consistent and ethical business practices, fostering an inclusive environment where all voices are heard.<\/p>\n

\u2022 Develop action plans based on surveys and evaluations to continuously improve stakeholder relationships and ensure sustainable business success.<\/p>\n

 <\/p>\n

Delegation of Authority<\/strong><\/p>\n

Our Delegation of Authority Policy is designed to clearly define the distribution of responsibilities and the delegation of authority within the organization, ensuring efficient decision-making and clear accountability. This policy applies to all levels of management and employees in the company, ensuring that each individual understands their roles and the limitations of their delegated authority.<\/p>\n

We establish clear definitions of the specific authorities and responsibilities assigned to different roles within the company, allowing for a transparent and functional organizational structure. Furthermore, we define both financial and operational approval limits for delegated authorities, ensuring that decisions are made within a controlled framework aligned with the company’s strategic objectives.<\/p>\n

We ensure that employees understand and assume responsibility for the decisions made under delegated authority. Therefore, we provide ongoing training so that employees understand the scope and limits of their authority, thus promoting responsible and effective management. We also conduct periodic reviews and oversight of delegation structures to ensure they remain effective and appropriate to the organization’s changing needs. This review process allows us to adjust and optimize the delegation of authority while maintaining operational agility and efficiency.<\/p>\n

 <\/p>\n

Independence of the Chairperson of the Board<\/strong><\/p>\n

Our Chairperson Independence Policy is designed to maintain impartiality and objectivity in the leadership and governance of our organization. This policy applies to the role and responsibilities of the Chairperson, ensuring that their position remains independent of executive management. To achieve this, we ensure the separation of roles, ensuring that the Chairperson does not perform executive management functions.<\/p>\n

In addition, we prevent conflicts of interest by requiring the Chairperson to disclose any potential conflicts that could affect their impartiality.<\/p>\n

We empower the Chairperson to make decisions objectively, free from undue influence from internal or external parties, thereby promoting fair and balanced governance. We implement term limits to encourage the incorporation of fresh perspectives and reduce potential biases, ensuring consistent leadership renewal.<\/p>\n

We also conduct periodic evaluations of the Chairperson’s performance and independence, ensuring that standards of impartiality and effectiveness in their leadership are maintained.<\/p>\n

Through these guidelines, we seek to ensure strong leadership and transparent governance that contribute to the success and sustainability of our organization.<\/p>\n

We are committed to fulfilling these voluntary commitments through mechanisms that ensure development and implementation. The ESG Working Group reports monthly to the Management Committee on ESG progress to ensure effective execution. ESG leads also report regularly to the Board of Directors and ESG experts on key indicators.<\/p>\n

We evaluate ESG risks as an integral part of our business management and make informed, responsible decisions. We maintain internal and external engagement mechanisms to continuously improve our sustainability policies and performance.<\/p>\n

 <\/p>\n

Versions and Approval<\/p>\n

This policy was approved by the Lyntia Networks administrators in September 2025<\/p>\n

Version: 3.0<\/p>\n

 <\/p>\n

 <\/p>\n

 <\/p>\n

Versions & Approval<\/p>\n

 <\/p>\n

This policy was approved by lyntia Networks\u2019 administrators on the 7th January 2025<\/p>\n

Version: 2.0<\/p>\n

 <\/p>\n

 <\/p>\n

 <\/p>\n

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