Modern Slavery and Human Trafficking Statement

The respect for human rights is self-evident and forms an integral part of the corporate culture of Lufthansa Group [1] as a group of companies that acts with responsibility and integrity. Modern slavery is a crime and a violation of fundamental human rights. We are committed to improving our practices to combat modern slavery and human trafficking. Our statement outlines the steps we have taken to prevent Modern Slavery within our Group and our supply chains and sets out our plans for future improvements.

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 (United Kingdom) and constitutes our Group's slavery and human trafficking statement for the financial year ending 31.12.2020.

In conformity with section 54 of the Act, in this statement we report about:

  • I.       About Lufthansa - our organizational structure
  • II.     Our policies regarding Modern Slavery and Human Trafficking
  • Ill.    The Human Rights Working Group and further safeguarding measures
  • IV.    The IATA resolution on Human Trafficking
  • V.     Our supply chains
  • VI.   Our further steps to prevent Modern Slavery
  • VII.  The approval for this statement

1. Our organizational structure

Lufthansa Technik AG is part of the Lufthansa Group. The Lufthansa Group is an aviation group with worldwide operations and 110,065 employees and more than 532 subsidiaries and affiliated companies as of 31.12.2020.

The portfolio  of  Lufthansa  Group comprises the  business segments  Network Airlines,  Eurowings and Aviation Services. All business segments rank among the leading providers in their respective industries.

Network Airlines

The Network Airlines segment comprises Lufthansa, SWISS, Austrian Airlines and Brussels Airlines. With their multi-hub strategy, the Network Airlines offer their customers a premium, high-quality product and service, and a comprehensive route network combined with the highest level of travel flexibility.

Eurowings

The Eurowings business segment includes the flight operations of Eurowings and Eurowings Europe, as well as the  equity investment in SunExpress.  With  Eurowings, the  Lufthansa  Group has an innovative offer for price• sensitive and service orientated customers in the structurally growing European direct traffic segment.

Aviation Services

The companies in the business segment Aviation Services are leaders in their worldwide markets and strengthen the  portfolio of the Lufthansa  Group. They include the business segments logistics, MRO and catering as well as other companies and Group functions.

Further information regarding the Company's structure may be found here

2. Policies

As a  participant of the UN Global Compact since 2002, the Lufthansa Group attaches great importance  in conducting its business in  line with internationally acknowledged principles and is committed to embedding respect for  human rights as an integral element of its corporate culture. The Group has a  large unionized workforce represented by a  number of different trade unions.

Our Group Companies consult with employee representative bodies, including trade unions and works councils. The binding  Code of  Conduct  documents  the  values,  principles and  standards  of conduct  of the  Lufthansa

Group. Point 6 expressly states, "We respect and uphold the dignity of our employees, customers, and business partners. In all our actions, we ensure that we act in accordance with human rights, the principles of the UN Global Compact, and recognize international labour and social standards. In particular, we reject child labour, forced  labour, and exploitation or discrimination of any kind." The Code of Conduct is binding for all bodies, managers and employees of the Lufthansa Group.

The companies are obliged to identify human rights risks and report the type and number of suspicious incidents. Individual complaints can be made by third parties to the external ombudsman - confidentially if requested. Furthermore Lufthansa Group advanced their plans for installing an electronic reporting channel for whistleblowers in 2020.  Employees of the Lufthansa Group can also report to their manager, human resources department or the employee representatives. A works agreement with regard to grievance procedures is already in place for all employees in Germany.

3. Human Rights Working Group and further safeguarding measures

A Human Rights Working Group was established within the Human Resources and Legal Affairs Division of the Executive Board in 2017  and comprises of representatives from all relevant head office functions and Group companies that are potentially at risk. The project group monitors and discusses any potential high and extreme risk areas, incidents and actions in relation to human rights with the specific field of modern slavery. The Working Group meets generally twice a year to monitor the Group's progress in tackling modern slavery.

Based on an analysis carried out by Verisk Maplecroft, an advisory company with recently renewed contract, an overview of all Group companies operating in high-risk and extreme-risk countries was drawn up, i.e. countries where the risk of human rights violations are particularly high. The country overview is regularly updated and regular meetings serve to communicate information and develop a  uniform, group-wide  position and strategy. Managers and Human Resources departments at these companies are made aware of their duty of care to avoid human rights violations and the  realization of risks due to  modern slavery. A specific annex was added to the employment contracts with these managers. In addition, awareness  is created by means of focused internal communication to all the employees in the Group. This includes a  statement by the  Executive  Board member for Corporate  Human Resources and Legal Affairs emphasizing the  responsibility of the  Lufthansa  Group as a global company that respects human rights. In 2020 the responsibility for Human Rights Compliance within Lufthansa Group was transferred from the Human Resources department to the Legal department.

4. IATA Resolution on Human Trafficking

As a  signatory to the  IATA Resolution against Trafficking in Persons, ensuring an environment that is free from modern slavery and human trafficking  is a  matter of course for the  Lufthansa Group. The legal  prosecution  of human trafficking  is the  responsibility of governments  and national  law enforcement agencies.  Nevertheless, the Lufthansa Group is aware of the importance of this topic and recognizes that as an aviation company it can play a significant role in identifying potential criminal offences. It has therefore implemented a reporting process for flagging suspected cases of human trafficking.

In accordance with  IATA recommendations, the Lufthansa Group has integrated the topic into regular pilot and flight attendant training in  2019. These employee groups are made particularly aware of potential signs of human rights violations. Due to the Corona pandemic, trainings have been paused temporarily in 2020. Steering and developing  the management approach is the responsibility of the Anti-Human Trafficking Task Force, established in 2018, in which all Group companies and relevant Group Functions are represented.

5. Our Supply Chains

To meet the standards the  Lufthansa Group sets for the sustainability of its own production and products, the Lufthansa  Group thus  relies on close co-operation  with  suppliers who share and implement these standards. This approach is also  part of the Lufthansa Group's Code of Conduct. The Lufthansa Group expects from its suppliers that they fully comply  with  current  law, guidelines and regulations  concerning fair competition, integrity and responsible practices.

The Group procurement policy includes the obligation to assume social and ecological responsibility. It is to be understood as an overriding specification for all procurement guidelines at the Group companies. In addition, it serves   as  a handbook for buyers and  all employees with contacts in the procurement markets. Among other considerations it is expected that these obligations are included in contracts with suppliers:

  • to comply with the ten principles of the UN Global Compact;
  • to comply with the four basic principles of the International Labour Organisation (ILO);
  • to consent to announced and unannounced audits by companies of the Lufthansa Group;
  • to accept the termination of the contract in the event that these contractual obligations are breached.

By imposing these obligations, the Lufthansa Group endeavors to ensure responsible practices by its direct suppliers  and so to meet its own standards for corporate responsibility. The Lufthansa Group's expectations on its suppliers  in terms of social and ecological responsibility are summarized and published in a Supplier Code of Conduct.

To identify the type and level of supplier risks, the procurement units responsible for product groups carried out a risk assessment for the suppliers. The outcome is included in the result of Group risk management. In addition, risk analyses based on expenditure and country were performed in 2019 for all direct suppliers. Suppliers in "extreme risk" countries were identified based on an overview of Verisk Maplecroft in order to develop plans for action.

6. Further Steps to Prevent Modern Slavery

The Lufthansa Group as  a  globally operating group of companies sees it as  its responsibility to contribute. Companies  do  not  control  political  developments  in  countries  they  operate  in;  however,  they  have   a responsibility in the sphere of their work, especially towards their employees worldwide. In the coming year, the Group will look to further improve its structures, practices and trainings to fight Modern Slavery and  Human Trafficking.

7. Approval for this statement

On 07. June 2021, this statement was approved by the Members of the Executive Board with respect to the Financial Year 2020.

Dr. Johannes Bussmann
Chairman of the Executive Board/CEO
 

 

[1] Lufthansa Group means Deutsche Lufthansa AG, and its related bodies corporate, as defined in Section 18 of the German Stock Corporation Act (Aktiengesetz)

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