Respect for human rights

Respect for human rights is a key issue for the Lufthansa Group

As an employer, the Lufthansa Group directly contributes to the livelihoods of more than 96,677 employees and their families worldwide. Its value chain also includes a large number of business partners whose employees contribute indirectly to the Lufthansa Group’s business success and may be dependent on it. This means that the Lufthansa Group shares responsibility for the concerns of its own workforce and, indirectly, for those of the employees along its value chain too. This is also reflected in working conditions at the Group companies, the guarantee of freedom of association and assembly, rules to ensure gender equality and the inclusion of minorities. It is also demonstrated in the expectation expressed in the Supplier Code of Conduct that the business partners included in the value chain should also adhere to the same principles.

The Lufthansa Group bases its business activities on internationally recognised standards such as the following:

- United Nations’ Universal Declaration of Human Rights

- Fundamental principles and core labour standards of the International Labour Organization (ILO)

- Ten principles of the UN Global Compact

- UN Guiding Principles on Business and Human Rights

- Sustainable Development Goals (SDGs)

- National Action Plan for Business and Human Rights (NAP)

- OECD Guidelines for Multinational Enterprises

- IATA Resolution against Trafficking in Persons

Risk management system for compliance with human rights and environment-related corporate due diligence requirements expanded

The Lufthansa Group has updated its established risk management system. As well as a regular risk analysis relating to its own companies, this now also involves an analysis of its supply chain. The scope of the audit, which was previously limited to human rights risks, has now been expanded to include selected environment-related risks. For example, an analysis is carried out to assess whether risks apply in terms of a violation of the Minamata Convention, which aims to restrict mercury releases and emissions, or the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal. A prevention and remedial action portfolio has been developed and integrated into an established process for use in case any risks or legal violations are identified. Based on the risk analysis findings, for example, an annex has been added to managers’ employment contracts for companies with a heightened level of risk. This contract annex obligates managers to ensure respect for human rights within their area of responsibility. The Lufthansa Group aims to fulfil its due diligence requirements both in its own business operations and throughout its supply and value chains, to the extent that it is able to exercise influence here. In addition, a concept has been developed for the Internal Control System which is intended to monitor compliance with the Company’s due diligence requirements.

Management submits policy statement on the Lufthansa Group’s human rights strategy

The Executive Board of Deutsche Lufthansa AG approved a policy statement on the human rights strategy of the Lufthansa Group in the reporting year. This policy statement reflects the Company’s commitment to ensuring respect for human rights. It describes how the Lufthansa Group fulfils its due diligence requirements, which high-priority human rights- and environment-related risks have been identified on the basis of the risk analysis and which human rights- and environment-related expectations apply to the employees of the Lufthansa Group and its suppliers. This is supplemented by the Lufthansa Group’s Code of Conduct, which applies to all board members, managers and employees of the Lufthansa Group, and its Supplier Code of Conduct. These two codes of conduct were revised in the reporting year and now also reflect the requirements of the German Corporate Due Diligence in Supply Chains Act (LkSG). ↗ Responsible supply chain management

Detailed reporting on ongoing management approach development aimed at minimising human rights violations

As part of its efforts to create transparency regarding the ongoing development of its risk management approach relating to human rights and in order to meet its reporting obligations, the Lufthansa Group publishes a declaration in accordance with the UK Modern Slavery Act 2015 in addition to an annual progress report as a participant in the UN Global Compact. The above declaration is available on the Lufthansa Group website. The Lufthansa Group regularly reviews whether it is also subject to reporting obligations under other regulations.

Lufthansa Group updates management approach for addressing 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. However, the 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 recognises 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 that has been approved by the authorities.

Moreover, the Lufthansa Group has developed web-based training in order to integrate these issues into regular training for flight personnel, in accordance with IATA recommendations. These employee groups are made particularly aware of potential signs of human rights violations. A review is currently under way as to whether this training needs to be updated. If necessary, it will be revised in the following year. The ongoing development of the management approach for combating human trafficking is managed by the Lufthansa Group Human Rights and Non-Discrimination Team in close cooperation with the Lufthansa Group’s Passenger Airlines and the relevant Group functions.

Processes for reporting human rights violations are implemented

The Lufthansa Group has set up external channels for reporting compliance violations and human rights- and environment-related violations via an electronic whistle-blower system and an ombudsperson. Individual complaints can be anonymously brought to the attention of the Lufthansa Group via these reporting channels. Lufthansa Group employees can also contact the Lufthansa Group Human Rights and Non-Discrimination Team, their supervisors, human resources management or the co-determination bodies directly. The internal grievance mechanism already established in the Lufthansa Group, which is set out in a works agreement for employees based in Germany and can be used for many different kinds of complaints, can also be used to lodge complaints regarding human rights violations.

Rules of procedure on how to handle reports of human rights violations in the Lufthansa Group are available on the Lufthansa Group website.

“Zero tolerance” for cases of sexual harassment and discrimination

Respect for one another is particularly important to the Lufthansa Group. This includes creating the conditions for a working environment for all employees that is free of discrimination, harassment and unequal treatment. The Lufthansa Group expects this principle to be reflected globally in the conduct of all employees towards one another and in their behaviour towards external third parties such as customers and suppliers. In particular, this is implemented through regular internal communication and the advisory services of the Lufthansa Group Human Rights and Non-Discrimination Team. This team also serves as a Group-wide reporting point for sexual harassment and discrimination. All reports are followed up according to the process described in the rules of procedure. Where appropriate, necessary disciplinary measures will be implemented.

Organisational foundations and responsibilities

The Lufthansa Group’s human rights officer is responsible for monitoring risk management for compliance with human rights- and environment-related corporate due diligence requirements. This person is supported by the Internal Audit department, which reviews the fulfilment of the due diligence requirements in the companies of the Lufthansa Group as well as the appropriateness of the risk management system. The human rights officer is based in the Human Resources & Infrastructure department and regularly reports to the responsible Executive Board function as well as to the Executive Board in the event of significant developments. The human rights officer also serves as the initial point of contact for authorities, policymakers, the business community and society concerning any human rights-related matters.

The Lufthansa Group Human Rights and Non-Discrimination Team and the procurement function jointly coordinate the activities of the Lufthansa Group in relation to its human rights responsibility. Among other tasks, these teams are responsible for carrying out the human rights- and environment-related Group risk analysis, in close cooperation with the operational business entities, and for processing complaints and continuously update the risk management system. They receive support from the Human Rights Steering Committee, which covers the compliance, procurement, sustainability and occupational safety functions as well as the human rights officer. This committee steers key decisions relating to the Lufthansa Group’s fulfilment of its corporate due diligence requirements. In addition, selected contacts are available within the core companies of the Lufthansa Group to address employees’ human rights-related questions and assist with implementing the Group-wide risk management system. They participate in a quarterly human rights information dialogue, which the Lufthansa Group Human Rights and Non-Discrimination Team organises for internal interfaces. In the purchasing function, coordinators have been appointed to cover the impact of the German Corporate Due Diligence in Supply Chains Act on the individual product group areas and airlines of the Group. A network has thus been established so that measures can be discussed and agreed on directly between suppliers and purchasers.

Human rights- and environment-related risks are to be avoided and violations ended

The ultimate objective of the management approach is to ensure that human rights are respected worldwide to the extent that this lies within the Lufthansa Group’s sphere of influence and responsibility thus particularily in the companies of the Lufthansa Group and its supply chains. At the same time, human rights violations in the Lufthansa Group and its supply chain must be avoided by means of organisational and process-based measures. If any such risk is identified, it must be minimised or, if a violation is detected, it must be terminated and its effects mitigated as far as possible.

Human rights- and environment-related risk analysis implemented

The Lufthansa Group Human Rights and Non-Discrimination Team implemented a risk analysis for its own activities in the reporting year. A software was used to determine a human rights- and environment-related risk for more than 400 companies and offices which fall within the scope of the German Corporate Due Diligence in Supply Chains Act. This risk was calculated on the basis of country and sector risk indicators and media reports. For companies with a heightened level of risk, a more in-depth risk analysis was implemented based on surveys. The risks were weighted and prioritised, while also taking into consideration information received via the Group’s reporting channels.

Mandatory trainings on human rights, diversity and inclusion established

Two web-based trainings (WBT) courses were developed in the reporting year. The “Human rights” WBT is intended to provide basic knowledge on the topic of human rights, the identification of risks and violations, and reporting channels. A further “Unconscious prejudices and intercultural awareness” WBT is designed to raise awareness of anti-discrimination along with the issues relating to diversity, equality and inclusion. This training is mandatory and takes place every two years as a preventive measure for employees and managers in companies with a heightened level of risk and for employees in areas where these topics have a strong practical relevance, such as procurement and human resources.

Information formats and campaigns for employees to be conducted

The Lufthansa Group Human Rights and Non-Discrimination Team held several information events in 2023. Through such events, new employees were deliberately made aware of the advisory services offered by the Lufthansa Group Human Rights and Non-Discrimination Team. In addition, employees concerned with compliance, corporate due diligence requirements or for whom this topic is of particular relevance (e.g. in the areas of human resources and procurement) were notified of current developments in the field of human rights- and environment-related risk management through the established, quarterly human rights dialogue of the Lufthansa Group Human Rights and Non-Discrimination Team.

In order to identify and terminate potential human rights- and environment-related risks and violations as early as possible, employees and managers were also informed of opportunities for raising complaints via a series of channels on the intranet. Comprehensive information is also available on the intranet pages of the Lufthansa Group Human Rights and Non-Discrimination Team and the procurement function.

Dialogue formats support the development of knowledge on corporate responsibility

In light of the introduction of the German Corporate Due Diligence in Supply Chains Act (LkSG) in the reporting year, cross-sector dialogues and discussions with the business community were used to share initial knowledge and experiences. For example, the Lufthansa Group Human Rights and Non-Discrimination Team regularly takes part in events such as the Peer Learning Group Human Rights of the UN Global Compact’s Germany network and econsense (Forum for Sustainable Development of German Business). In the reporting year, the Lufthansa Group’s human rights officer also teamed up with econsense to set up a Human Rights Officer Roundtable specifically geared towards human rights officers, with the goal of exchanging experience on effective risk management.

Performance indicator

The Lufthansa Group will analyse and implement suitable indicators in line with its targets in 2024.

Lufthansa Group Annual Report 2023