Metrics and targets

G1-4 - Incidents of corruption or bribery

In 2024, there were zero convictions and EUR 0 in fines imposed on the Lufthansa Group for violations of anti-corruption or anti-bribery regulations.

The Lufthansa Group does not tolerate any violations of its anti-corruption and anti-bribery regulations. Should an investigation confirm a violation of applicable anti-corruption or anti-bribery regulations, the Lufthansa Group will take appropriate measures, taking into account the individual circumstances of each case. This may include disciplinary measures, claims for damages, increased training and awareness-raising activities, extraordinary internal audits, improvements to the standards concerned and processes to prevent future violations.

G1-5 - Political influence and lobbying activities

The following are representatives of the Lufthansa Group who are active in connection with political influence or lobbying activities of the Group:

No estimation was necessary for collecting the data in Table G1-5 29b) i).

The following are the main topics of the Lufthansa Group that are subject to its lobbying activities:

Reform of EU Air Passenger Rights Regulation 261/2004 according to the 2013 Commission proposal

The Lufthansa Group advocates implementing the Commission’s 2013 proposal to reform EU Regulation 261/2004 in its current form. This particularly includes the definition of extraordinary circumstances and the adjustment of delay threshold values.

Finance SAF quota through uniform levy

From 2025, the quota for sustainable aviation fuel (SAF) applies to flights to and from European airports. The Lufthansa Group is lobbying for the equal financing of the SAF quota by European and non-European aviation companies, for example through a uniform European SAF levy calculated based on total travel distance.

Expand free SAF certificates

The Lufthansa Group advocates expanding the period and number of free SAF certificates for aviation in European emissions trading.

Use aviation tax for SAF promotion

The Lufthansa Group advocates that aviation tax revenues in the 2025 Budget Act should be used to promote SAF.

Introduce European support strategy for SAF

The Lufthansa Group advocates introducing a support strategy for the production and use of SAF at the European level.

Introduce Book & Claim mechanism for SAF use

The Lufthansa Group advocates introducing a Book & Claim mechanism to meet SAF quotas. This involves trading SAF certificates to bring sufficient SAF into circulation regardless of location.

Introduce single European airspace

The Lufthansa Group advocates introducing a single European airspace with politically independent European regulatory authorities and independent national supervisory authorities.

Maintain advance payment practice

The Lufthansa Group advocates maintaining the advance payment practice for flight ticket purchases.

Make provision of aircraft data to airlines mandatory

The Lufthansa Group advocates that aircraft manufacturers must enable airlines to access, control and use data generated during flight operations.

Maintain European regulation on common rules for slot allocation at airports

The Lufthansa Group advocates that the European regulation on slot allocation at airports should be maintained in its current form and, if at all, only be adjusted uniformly based on recommendations from international organisations.

Create legal basis for modernising aviation security controls

The Lufthansa Group advocates creating a regulatory basis at the European level for automatic detection of dangerous objects during security screening and advancing certification.

Revise EU Regulation 1069/2009 (health rules for animal by-products not intended for human consumption)

The Lufthansa Group advocates revising EU Regulation (1069/2009) to the effect that waste on international flights containing animal (by-)products does not have to be incinerated or landfilled.

Maintain flight route technology ADS-C EPP obligation

The Lufthansa Group advocates maintaining the obligation to use Automatic Dependent Surveillance – Contract Extended Projected Profile (ADS-C EPP) flight route technology as mandatory across Europe.

Connect German airports to high-speed rail routes

The Lufthansa Group advocates connecting German airports to Deutsche Bahn AG’s high-speed routes and long-distance network.

Examine application of Carbon Border Adjustment Mechanism (CBAM) in aviation

The Lufthansa Group advocates examining the application of this CO₂ border adjustment system in aviation as part of EU climate policy.

Introduce prioritised air traffic control clearances

The Lufthansa Group advocates inserting a legal basis for granting prioritised air traffic control clearances according to the “Best Equipped Best Served” (BEBS) traffic control principle into the air traffic control implementation regulation. BEBS provides incentives for aviation companies to convert their fleet to innovative technologies more quickly. In return, airlines are offered preferential treatment to avoid losing the climate-friendly effect in a lengthy landing procedure.

Limit non-CO₂ effects in EU Emissions Trading System (ETS)

The Lufthansa Group advocates limiting the scope of EU ETS for non-CO₂ effects to intra-European flights.

Delete national quota for Power-to-Liquid fuels in Federal Immission Control Act (BImSchG)

The Lufthansa Group advocates abolishing the national Power-to-Liquid (PtL) fuel quota for aviation in Section 37a Paragraph 4a BImSchG as part of the national implementation of the Renewable Energy Directive.

No introduction of a kerosene tax

The Lufthansa Group advocates not introducing a kerosene tax under the Energy Tax Directive.

Consider including aviation in German and European carbon management strategy

The Lufthansa Group advocates including aviation in Germany’s and the EU’s carbon management strategy.

Close EU legislative gaps in working conditions

The Lufthansa Group advocates closing legislative gaps that enable fictitious home bases, false self-employment and the abusive posting of employees.

Reform strike law

The Lufthansa Group advocates reforming strike law regarding announcement periods, emergency service agreements and mandatory conciliation procedures.

Make employment references transmittable via text form

The Lufthansa Group advocates adapting the German Trade regulation Act to allow employment references to be transmitted via text form (instead of exclusively in written form).

Make essential contractual terms transmittable in text form

The Lufthansa Group advocates that essential contractual terms of employment relationships can be transmitted in text form – for example via email – instead of written form.

Introduce weekly working hours

The Lufthansa Group advocates changing the consideration of working time from a daily to a weekly perspective.

Design reporting obligations in the implementation of the EU Pay Transparency Directive with minimal bureaucracy

The Lufthansa Group advocates for reporting obligations in implementing the EU Pay Transparency Directive to be implemented unbureaucratically and privileges created for collective bargaining parties.

Do not transfer costs for document changes related to the German Self-Determination Act to employers

The German Self-Determination Act is intended to make it easier to change gender entries and first names. The Lufthansa Group advocates for the financial costs for changing documents to no longer be borne by the employer in the future.

Privilege collective bargaining parties in implementing the EU Corporate Sustainability Due Diligence Directive (CSDDD)

The Lufthansa Group advocates for collective bargaining parties to receive privileged status in the national implementation of the CSDDD.

Transpose EU Corporate Sustainability Reporting Directive (CSRD) unchanged into German law

The Lufthansa Group advocates for the national implementation of the CSRD to be transposed one-to-one into German law.

No further increase in location costs through state fees

The Lufthansa Group calls for a moratorium on charges for air traffic. Specifically, there should be no foreseeable fee increases. Additionally, the costs for hazard prevention should be borne by the state.

Allow import of ungulate species by air freight into the EU

The Lufthansa Group advocates allowing temporal separation of different ungulate species in animal border control posts and other EU import facilities as effective protection against cross-infection in addition to spatial separation according to Commission Implementing Regulation (EU) 2019/1014 and Regulation (EU) 2017/625.

Maintain proportionality in German requirements for aviation security training

The Lufthansa Group advocates maintaining proportionality in German requirements for aviation security training according to the Aviation Security Training Ordinance of 6 July 2023 (Federal Law Gazette 2023 I No. 193) in the course of Commission Implementing Regulation (EU) 2015/1998, Point 11.4.3 as in EU neighbour countries.

Introduction of an offsetting model for import VAT collection in Germany

The Lufthansa Group advocates introducing an offsetting model for import VAT collection according to EU VAT System Directive 2006/112/EC Article 211 – as in most EU neighbour countries – for fairer competition conditions within the EU, cost reduction for the economy, strengthening logistics and avoiding unnecessarily long transport routes for goods imports.

Digitalisation of data exchange including with authorities along the air cargo transport chain

Along the air cargo transport chain, data exchange, for example with authorities, should be fully digitalised and preferably according to an international data standard. This can ensure more transparency, efficiency and security in the transport chain. The Digital Test Field Air Cargo project, with Lufthansa Cargo’s participation, supported by the German Federal Ministry for Digital and Transport, contributes to this.

Maintenance and application of Aviation Act regulations

The Lufthansa Group advocates maintaining the approval procedures for occasional traffic or ad-hoc charter flights in air cargo for third-country airlines according to regulations, particularly in the German Aviation Control Act.

Promotion of aviation research especially for a more sustainable aviation industry

Lufthansa Technik advocates for aircraft maintenance, repair and overhaul areas to receive greater emphasis in the context of aviation research, to achieve and pursue more sustainable aviation earlier with short- and medium-term technologies alongside long-term innovations.

Establish Lufthansa Group as strategic partner for security policy “turning point”

A central element of the so-called “turning point” is the search for industrial partners to secure German defence capabilities in the long term. For the Lufthansa Group, value-oriented and responsible action is not just an aspiration but an integral part of its self-understanding. As a company rooted in Germany, it sees itself in a key role of strengthening the political and economic sovereignty and resilience of the Federal Republic and its armed forces in the long term.

Registration of the Lufthansa Group in the transparency register

The Lufthansa Group is registered in the following transparency registers:

European Union

• Lufthansa Group, EU Transparency Register 0714344663-32
• Brussels Airlines, EU Transparency Register 755555322381-50

Germany

• Deutsche Lufthansa AG, Lobby Register of the German Bundestag, Register number R001474
• Eurowings GmbH, Lobby Register of the German Bundestag, Register number R001213
• Lufthansa Cargo AG, Lobby Register of the German Bundestag, Register number R000854
• Lufthansa Technik AG, Lobby Register of the German Bundestag, Register number R003164

Austria

• Austrian Airlines, Lobbying and Interest Representation Register, LIVR-00193

Former public administration employees in administrative, management and supervisory bodies of the Lufthansa Group

The following employees in administrative, management and supervisory bodies of the Lufthansa Group held a comparable position in public administration, including regulatory authorities, in the two years before their appointment during the current reporting period:

• Tom Benedict
• Alexander Holzrichter
• Anna Maaßen

G1-6 - Payment practices

The Lufthansa Group aims to implement payments to all suppliers within the contractually agreed payment framework and in accordance with the Lufthansa Group’s payment terms. The Lufthansa Group does not differentiate between different suppliers in this regard.

The Lufthansa Group’s standard payment term is 30 days if not specified in the contract or on the invoice. The other two standard payment terms are 60 and 90 days. Generally, there is no further categorisation of suppliers regarding payment terms at the Lufthansa Group. The average payment period at the Lufthansa Group is 41 days.

For standard contract payment terms, payments are calculated from the date of invoice receipt. In the standard portfolio, payment terms can also be chosen that are calculated from the date of invoice issuance. Furthermore, timely payment is a control indicator with a target of 92%, based on the number of invoices. For all suppliers within scope, the Lufthansa Group additionally grants a grace period of seven days, which still counts as timely payment. Payment terms of more than 30 days require individual agreements in some countries.

The Lufthansa Group monitors payment outflows and thus the time until settlement of an invoice Group-wide through system reports on a monthly basis. The results are exchanged with the Lufthansa Group’s business units in monthly coordination meetings for continuous improvement, and any need for action is discussed. Additionally, payment runs are set up to enable regular payment transactions through the existing banking systems.

The current number of pending legal proceedings for late payment is zero for the year 2024 at the Lufthansa Group.

Suppliers have several options for contacting the Lufthansa Group regarding payment queries – for example, by contacting the accounting team or by checking the status in a supplier system where data can be self-managed and viewed.