The Lufthansa Technik Compliance Program currently consists of the components Integrity, Competition and Embargo Compliance and is applied in the whole Lufthansa Technik Group. While Integrity Compliance refers to economic criminal law, the Competition Compliance Guideline ensures the observance of antitrust and competition laws and regulations. The aim of embargo compliance is to ensure adherence to sanction regulations in foreign trade and international air transportation.
The Integrity Compliance Guidelines establish general principles for anti-corruption measures and provides a framework for employees of Lufthansa Technik Group regarding the acceptance and granting of benefits, invitations and gifts.
An invitation to events is a special form of a benefit and therefore is regulated in a separate Event Management Guideline. The Event Management Guideline provides a framework for employees of Lufthansa Technik Group for invitations of third parties to events, either organized by Lufthansa Technik Group or to external events. The Event Management Guideline is complemented by a checklist that must be filled in and archived by employees of Lufthansa Technik Group prior to addressing any invitation to an event to a third party.
The Guideline Gifts, Invitation to Meals and other Benefits gives guidance to Lufthansa Technik Group employees on provision of presents and gifts, inviting third parties to lunches and dinners and any other benefits Lufthansa Technik Group employees wish to provide to an external party.
The Conflict of Interest Guidline provides regulations for Lufthansa Technik Group employees, which have to be followed when they are offered any benefits, e.g. invitations to events or meals, gifts or any other benefits. Furthermore, the Guideline covers any other potential conflict of interest such as private relationships to business partners.
The Donations, Sponsorships and Memberships Guideline defines measures in order to avoid that no payments are used to influence any decisions by business partners or public officials.
The Competition Compliance Guideline familiarizes employees of Lufthansa Technik Group with antitrust and competition laws and regulations.
In consideration of steadily increasing significance of restrictions in cross-border business activities, Lufthansa has issued an embargo compliance guideline designed to create a binding framework for our business transactions and projects.
Electronic Whistleblowing System
Human rights risks, human rights violations, the violation of environmental obligations, Economic crimes and other illegal business practices are extremely damaging for those affected, the Lufthansa Technik Group and society. Your report can help to discover risks and detect misconduct, put an end to it and prevent damage from happening.
If you have reasonable grounds to suspect that employees or executives of the Lufthansa Technik, a supplier or sub-supplier are committing breaches of due diligence or compliance violations such as:
- Human rights violations (child labour, forced labor or modern slavery, unequal opportunities, disregard of occupational health and safety obligations, violations of freedom of association, withholding of an adequate wage, etc.)
- Violations of environmental obligations (especially in the area of hazardous waste, mercury or persistent organic pollutants)
- Economic crimes (corruption, fraud, embezzlement, money-laundering etc.)
- Infringements of competition, anti-trust and state aid laws
- Insider trading or market manipulation
- Conflicts of interest
- Embargo or export control breaches
- Data protection violations
please use our electronic whistleblowing system or contact our ombudsperson. We have also set up the e-mail address firstname.lastname@example.org for tips on human rights violations or the violation of environment-related obligations.
Information on human rights risks, human rights violations or the violation of environment-related risks will be handled by the Lufthansa Group in accordance with the provisions of the Lufthansa Group's Rules of Procedure pursuant to Section 8 of the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz).
With the help of our electronic whistleblowing system you can easily, safely and if you wish anonymously report an incident. The system enables you to send encrypted and secure messages to the Lufthansa Group Corporate Compliance Office.
Further information, including access to the system can be found here
The Ombudsman is a freelance attorney who is not an employee of the Lufthansa Group. As a neutral, independent contact, the Ombudsman takes complaints in writing or by telephone and provides them to the Corporate Compliance Office in an anonymized form, if this is what the complainant wishes. The identity of the complainant is protected by attorney-client privilege. Moreover, the Lufthansa Group has contractually agreed not to request access to any legally privileged information and to be informed of the complainants´ name only following his/her express consent.
Further information can be found here
Last modification 08 April 2022