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Code of Conduct Contents Code of Conduct Contents 1 We observe the rules of fair competition 4 2 We combat corruption 5 3 We comply with foreign trade requirements 6 4 We respect rules against market abuse 7 5 We have an ombudsman system 8 6 We act in accordance with human rights, 9 labor standards and social standards 7 Protecting the environment is important to us 10 8 We are vigilant about product safety 10 9 We maintain privacy protections and safeguard trade secrets 11 10 We obey laws to combat money laundering 11 11 We pledge to protect company assets 11 2 | Lufthansa Group Code of Conduct Preface by the Executive Board of the Deutsche Lufthansa AG Responsible and lawful conduct is an essential component of our corporate culture and the cornerstone on which we base our daily work. The Executive Board of Deutsche Lufthansa AG has adopted this Code of Conduct as the foundation of a set of values for Lufthansa Group and reports to the Supervisory Board on a regular basis. The principles embedded in this Code of Conduct are not just the basis of fair competition, they also help us detect and avoid legal and reputational risks. The Code of Conduct sets a framework within which we make decisions as a company, and guidelines according to which we orient our conduct and against which we are measured. To ensure the continued existence of a corporate culture based on trust and integrity, and to ensure the lasting success of our company, this Code of Conduct is binding upon all bodies, executives, and employees of Lufthansa Group. We expect our business partners, and especially the contractors and suppliers who work for us, to adhere to the principles embedded in this Code of Conduct. We all are called upon to observe this Code of Conduct and, where there is doubt, to obtain supplementary information and advice from the responsible people (for instance managers or the Lufthansa Group Compliance Office). Violations of this Code of Conduct will not be tolerated and may result in disciplinary measures and potentially even state-imposed sanctions. Harry Hohmeister Ulrik Svensson Carsten Spohr Dr Bettina Volkens Thorsten Dirks Member of the Executive Board Member of the Executive Board Chairman of the Executive Board Member of the Executive Board Member of the Executive Board Hub Management and Chief Financial Officer and CEO Corporate Human Resources Eurowings and and Legal Affairs Aviation Services Lufthansa Group Code of Conduct | 3 We observe the rules 1 of fair competition As a globally active corporate group, We refrain from any prohibited exchange we are in constant competition. of competition-sensitive information or Fair competition is indispensable for us, coordinated conduct with competitors. as the long-term success of our company can only be ensured through lawful and We likewise refrain from making honest competition. agreements with competitors regarding non-competition, restrictions on One of the fundamental principles of business relationships with suppliers, Lufthansa Group is therefore that all of its submission of bids in tender processes, bodies, executives, and employees act in or the division of customers, markets, accordance with the relevant provisions regions, or product portfolios. under competition law. The standard we hold ourselves to is that we do not make or tolerate agreements with competitors regarding prices, price increases, terms and conditions or capacities, profits, profit margins, costs, sales and marketing measures, or other competition-relevant factors. 4 | Lufthansa Group Code of Conduct 2 We combat corruption The Lufthansa Group companies and In our understanding, a conflict of interest their employees act in a responsible is already present if the relevant person’s manner and fight against all forms of objective decision-making ability could bribery and corruption. be influenced by his or her own interests or the interests of third parties and there Both in the initiation and in the is the risk that business decisions will no maintenance of business relationships, longer be made for the exclusive benefit we base our decisions solely on objective of our company. criteria and allow ourselves to be guided neither by personal interests or relati- We therefore avoid situations that might onships nor by material or immaterial suggest a conflict of interest or the personal advantages. appearance of a conflict of interest. Our goal is to avoid even the appearance We are aware of the risk that donations, that gifts of any kind might be conside- sponsoring activities, or memberships red or construed as compensation for a may mask corrupting payments. certain desired behavior. This is particularly true in our dealings with government officials. We therefore refrain from demanding, promising, granting, or accepting any material or immaterial advantages as compensation for the procurement of products or services. Furthermore, all bodies, executives, and employees of Lufthansa Group companies are obligated to ensure that their business decisions remain free of conflicts of interest and are made exclusively in the best interests of Lufthansa Group. Lufthansa Group Code of Conduct | 5 We comply with 3 foreign trade requirements Our principles also include strict As a globally active company, we comply adherence to national and international with the export control laws that are embargoes on countries and individuals. currently applicable. All bodies, Embargoes that restrict the freedom executives, and employees of Lufthan- of foreign trade with certain countries sa Group are obligated to familiarize may be imposed for foreign policy and themselves with and adhere to the laws security policy reasons. governing import and export control. In our contracts involving the granting of funds and/or economic resources, we therefore take care not to violate any embargoes. 6 | Lufthansa Group Code of Conduct We respect rules 4 against market abuse In the course of our activities, it may We are aware of our responsibility in occur that we gain access to inside the event of knowledge of inside information regarding our company or information and commit ourselves to our business partners that is not publicly particular discretion and restraint. known. The bodies, executives, and We therefore refrain from using inside employees with regular access to inside information to our own benefit or disclo- information in their daily work environ- sing it to unauthorized third parties. ment have received comprehensive information regarding the legal To ensure responsible review and obligations arising from their access to decisions regarding the lawful handling such information, and regarding the of potential inside information and to legal consequences of violations. fulfill any existing ad hoc reporting duties, Deutsche Lufthansa AG has appointed an ad hoc committee. Lufthansa Group Code of Conduct | 7 We have 5 an ombudsman system To allow for the confidential submission of transmitted to him to the Lufthansa Group information regarding potential offences Compliance Office and to Group or violations of laws or rules applicable to Security. The identity of the whistleblower our business, Lufthansa Group has may only be disclosed to the Lufthansa established an ombudsman system. Group Compliance Office or third parties The Lufthansa Group ombudsman is an if expressly permitted by the whistle blower external attorney. He relays all or ordered by public authorities. compliance-relevant facts that are 8 | Lufthansa Group Code of Conduct We act in accordance with human rights, 6 labor standards and social standards We respect and uphold the dignity of our Free choice of occupation, equal pay, employees, customers, and business and the right to rest and take regular paid partners. In all our actions, we ensure vacations are firmly embedded in our that we act in accordance with human company. It is important to us to promote rights, the principles of the UN Global and preserve the health and safety of our Compact, and recognized international employees. labor and social standards. We promote social security in our sphere In particular, we reject child labor, forced of responsibility and respect the right labor, and exploitation or discrimination to freedom of opinion and freedom of of any kind. We support the right of free expression. assembly, freedom of association, and collective bargaining, as well as the relevant regulations to ensure fair working conditions. Lufthansa Group Code of Conduct | 9 Protecting the 7 environment is important to us We rise to the challenge of responsibly Following the environmental guidelines shaping modern mobility and its related of Lufthansa Group, and maintaining services. To continuously reduce the and gradually expanding the certified, detrimental environmental effects of our validated environmental management business activities, we deploy the neces- system are an essential foundation for sary resources as efficiently as possible this and, at the same time, the primary and work towards the development and instrument for managing and continuous- proliferation of environmentally friendly ly improving our environmental perfor- technologies. mance. We are vigilant 8 about product safety In creating our products and providing great care to only use upstream products our services, we fulfill the legal and and materials of absolutely certain origin company-internal requirements and take and suitability. Datenschutz und 10 | Lufthansa Group Code of Conduct We maintain privacy protections 9 and safeguard trade secrets We only collect, process, and use The success of Lufthansa Group is also personal data to the extent required for dependent on its handling of confidential legitimate and clearly defined purposes. information. Data and information we Moreover, to maintain the confidentiality gain access to on an operational level of personal data, we enforce high may only be used to the permitted extent. standards regarding the secure use, Such information may only be disclosed retention, and storage of data and trans- once it has been determined that the mit such data only under the condition recipient is authorized to receive this that there is a legitimate reason and that information.
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