Statement of the Lufthansa Cargo Executive Board.

Integrity and adhering to laws and regulations is a core principle of all our business activities. This is particularly true regarding strict adherence to antitrust and anti-corruption regulations. We follow the clear guideline that we will rather not go ahead with a deal than to infringe laws or regulations.
To implement this a comprehensive Compliance Program was set up for the whole Lufthansa Group. Please refer with any questions to the Compliance Office, who will support you with any issue. Effective Compliance requires the support of all of us!

Dorothea von Boxberg
Ashwin Bhat
Harald Gloy

Lufthansa Group Compliance Program.

Compliance describes all measures taken to ensure the correct conduct of companies, their management and staff with respect to statutory and the Company’s own obligations and prohibitions. The Lufthansa Group Compliance Program is intended to prevent staff and the Company from coming into conflict with the law and at the same time to help them to apply statutory regulations correctly. 

The Lufthansa Compliance Program is made up of the following elements: Competition, Capital Markets, Integrity, Embargo and Corporate Compliance. An ombudsman system gives staff the opportunity to report any suspicion of criminal activity or breaches of the compliance regulations. The central Compliance Office, which reports to the Board member responsible for Human Resources and Legal, the various central and local compliance committees in the Lufthansa Group and the Compliance Officers in Group companies, among others, ensure that the Lufthansa Compliance Program is enforced throughout all companies in the Lufthansa Group by means of regular online training courses and information published on the intranet. The Audit Committee of the Supervisory Board is notified semi-annually of incidents and progress concerning compliance in a Compliance Report.

Lufthansa Group Code of Conduct.

Responsible and lawful conduct is an essential component of our corporate culture and the cornerstone on which we base our daily work.
Therefore 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.

What is a code of conduct?
A code of conduct is a code of behavior. It sets out a company’s expectations in terms of the behavior of its managers and employees. For instance, codes of conduct generally include instructions on dealing with competitors as well as anti-corruption rules and provisions relating to compliance with labor standards and human rights. 

The Lufthansa Group Code of Conduct establishes a binding framework for all of the Group’s managers and employees. This is concretized through policies such as the Group’s Integrity and Competition Compliance Guidelines.

For more information regarding the Lufthansa Group Code of Conduct please click here.

Reporting and Ombudsman System.

With a view toward ensuring the reporting of information about potential violations of laws or regulations applicable to the conduct of our business (corruption/bribery, fraud, competition and antitrust laws), Lufthansa Group has set up an ombudsman system. This is an additional preventive measure to ensure legal and ethical business conduct and to help protect Lufthansa Group and its staff. The ombudsman function is performed by an external lawyer who is not a Lufthansa Group employee. The concerned party can submit information to the ombudsman by phone, in writing (email, letter, fax), or in person. The aim is a personal meeting or a personal telephone conversation between the ombudsman and the concerned party. If a concerned party prefers not to disclose his/her identity to Lufthansa, the ombudsman will report the facts brought to his attention to Lufthansa while keeping the concerned party's name and identity confidential.

In fact, Lufthansa Group and the ombudsman have expressly agreed to waive the disclosure of the concerned party's identity and the surrender of any records and other information obtained, unless the concerned party explicitly agrees to disclosure. This rules out any disclosure of the concerned party's identity to Lufthansa without his/her consent. Further, unless disclosure is required by law, the ombudsman will not disclose the name and identity of the concerned party to any third party without the concerned party's consent.  

Contact details of the Ombudsman:
Dr. Buchert Rechtsanwaltsgesellschaft mbH

Tel: +49 69 710 33 33 0
Tel: +49 6105 92 13 55
Fax: +49 69 710 34 44 4
dr-buchert@dr-buchert.de
www.dr-buchert.de

The Ombudsman can be reached free of charge with this number: +800 5757 6868

For calls from the following countries these numbers apply:
USA: 1 855 683 1416
Egypt: 0800 0000782
Chile: 1230 0201011
India: 000800 1005779
Mexico: 0 1800 1231861
Romania: 0800 896151
Ukraine: 0800 503342

For more information on the reachability of the hotline or the ombudsman system please click here.