Impact, risk and opportunity management

S1-1 – Policies related to own workforce

The Lufthansa Group sets new priorities with its HR strategy

The Lufthansa Group human resource strategy focuses on the following six pillars:

• Modern and flexible career paths
• New forms of work
• A contemporary leadership culture and diversity
• Sustainable employability
• Trust-based collective bargaining partnerships
• Competitive staff costs

The Lufthansa Group reviews its human resource strategy every year on the basis of the prevailing framework conditions. New priorities are set as required by incorporating them into operations through targeted actions. The strategy applies worldwide to all employees of the Lufthansa Group. Annual employee surveys engage the workforce in further developing the strategy. Continuous monitoring tracks the actions and performance indicators derived from the strategy. The Executive Board of Deutsche Lufthansa AG bears ultimate responsibility for implementation of the strategy.

Policy statement sets out the Lufthansa Group’s human rights strategy

The Lufthansa Group’s policy statement on the German LkSG outlines the Company’s human rights strategy. It also reports how the Lufthansa Group fulfils its due diligence requirements, which high-priority human rights- and environment-related impacts have been identified as high priorities on the basis of the risk assessment and which human rights- and environment-related expectations apply to the employees of the Lufthansa Group and its suppliers. ↗ S2-1 – Policies related to workers in the value chain.

The policy statement is updated and published annually in line with the impact assessment conducted during the reporting year. To prevent negative impacts on human rights or the environment, the Lufthansa Group reviews the effectiveness of its prevention and remedial measures on an ad hoc basis – at least annually – and makes adjustments as necessary. This process includes evaluating feedback from affected parties, gathering input from target groups and conducting audits. In addition, an active exchange is sought with internal stakeholder groups such as employee initiatives and staff representative bodies, as well as with external stakeholders.

The Lufthansa Group pursues a two-pronged strategy to protect human and environmental rights. On the one hand, it aims to prevent impacts from occurring in the first place. On the other hand, it tries to respond to structural impacts identified in the analysis with appropriate actions to prevent or at least minimise adverse consequences for human rights and the environment. If the Lufthansa Group becomes aware of an actual or imminent breach of human rights or environmental obligations, it immediately strives to take appropriate remedial action. If a supplier is unable to immediately cease, prevent or minimise a breach, the Lufthansa Group will develop and implement a corresponding remedial and/or prevention plan. When developing and implementing the plan, the joint development and execution of a corresponding plan with the responsible company to eliminate or reduce the breach is considered, as is collaborating with other companies through industry initiatives and standards to increase influence over the company behind the breach, and the temporary suspension of the business relationship for the duration of risk mitigation efforts. As a last resort, the Lufthansa Group reserves the right to terminate the business relationship.

The international conventions and declarations listed below form the framework for the Lufthansa Group’s actions in connection with the requirements of the German Corporate Due Diligence in Supply Chains Act and apply to the relevant Lufthansa Group guidelines:

• United Nations’ Universal Declaration of Human Rights,
• the International Covenant on Civil and Political Rights (ICCPR), the International Covenant on Economic, Social and Cultural Rights,
• the four core work standards of the International Labor Organization (ILO),
• the UN Guiding Principles on Business and Human Rights,
• the ten principles of the UN Global Compact,
• the OECD Guidelines for Multinational Enterprises,
• the IATA Resolution against Human Trafficking, and
• environmental agreements such as the Minamata Convention on Mercury, the Stockholm Convention on Persistent Organic Pollutants and the Basel Convention on the Transboundary Movement of Hazardous Wastes and their Disposal.

The Lufthansa Group’s Code of Conduct is founded on ethical values

The Lufthansa Group’s Code of Conduct supports employees in making decisions that align with the Company’s principles and values. For customers, business partners and shareholders, the Code of Conduct describes what the Lufthansa Group stands for as one of the leading aviation groups. It is binding for all employees of the Lufthansa Group worldwide, regardless of their role or level. Violations of the Code of Conduct can lead to severe penalties for the Company and for individual employees. The Code of Conduct is updated by the Chief Compliance Officer of the Lufthansa Group and approved by the Group Executive Board. It is available on the Lufthansa Group website.

The Code of Conduct covers topics such as fair competition as the foundation of business success, respect for human rights, occupational safety and health, anti-corruption measures, handling conflicts of interest, digitalisation and data protection, and external communication on social networks.

In accordance with the Code of Conduct, the Lufthansa Group treats employees and other stakeholders with respect and rejects all forms of discrimination, harassment and violence. Conduct within the Lufthansa Group is based on valuing and including people regardless of their national or ethnic background, gender, religion, beliefs, disability, age or sexual identity. The Company therefore opposes discrimination of any kind.

The Code of Conduct also includes information for anonymous whistleblowers and ensures their protection. A central complaints procedure has been set up to allow individuals to inform the Lufthansa Group about human rights and environmental risks – whether within a Lufthansa Group company or concerning one of its suppliers – on the basis of the publicly available rules of procedure. In these rules of procedure, the Lufthansa Group sets out clear guidelines to ensure the careful and transparent handling of every complaint. The aim of the complaints procedure is to receive information on human rights or environmental risks within the Lufthansa Group and its suppliers at the earliest possible stage to ensure measures can be introduced to avoid any corresponding violations. The complaints procedure also ensures that affected parties have access to appropriate remedial measures as far as this is possible for the Lufthansa Group.

The Lufthansa Group’s occupational safety guideline protects health

The globally applicable Lufthansa Group occupational safety guideline provides the central framework for safety and health at work in the Lufthansa Group. It requires that board members, managers and employees fully comply with the applicable occupational health and safety rules worldwide. The objective is to protect employees, contractors, and third parties from health risks. This includes work-related accidents and occupational hazards, as well as ensuring humane working conditions. The guideline covers all relevant regulatory content, outlines responsibilities, describes the organisational structure of the occupational safety function, and defines escalation levels and approval requirements.

The effectiveness of the guideline is monitored by the Occupational Safety Committee (OSC), the central steering committee for all issues concerning health and safety at the Lufthansa Group. The OSC includes, in addition to the Lead Safety Engineer, safety experts responsible for flight operations, MRO, logistics, ground operations, administration (office tasks), hazardous substances management and select safety coordinators from subsidiaries. The Lead Safety Engineer (Vice President Occupational Safety) bears ultimate responsibility for implementation of the guideline.

Group works agreement “Lufthansa and Family” governs work-life balance

The Group works agreement “Lufthansa and Family” governs work-life balance at the Lufthansa Group. The agreement seeks to align business requirements with family needs. In addition to counselling services, statutory parental leave, and options for reduced working hours, the agreement grants employees dedicated family time to focus solely on caring for relatives or partners. This family time leave entitlement may be taken for up to 364 days.

S1-2 – Processes for engaging with own workforce and workers’ representatives about impacts

Since 2015, the Lufthansa Group has conducted the annual employee survey “involve me!”, alternating between a full survey and a shortened version every two years. The survey is sent directly to employees and can be answered anonymously and voluntarily. The resulting engagement index provides insight into employer attractiveness and measures employee satisfaction and motivation. It also enables a cross-industry comparison with other employers. In addition, the survey measures the extent to which employees identify with the Company, as well as their level of commitment and their willingness to recommend the Company to others. The survey was carried out again in 2024. The results of the engagement index are measured on a scale from 5 (best) to 1 (worst). In 2024 the Company reached its target once again – the 2023 value of 3.8. In 2024, the evaluation methodology was adjusted to permit comparisons with other companies. Until 2023, the best possible score was 1 and the worst was 5; according to this methodology, the 2024 engagement index was 2.2.

The results of the employee survey are presented to the Executive Board and Supervisory Board of the Lufthansa Group. The management teams of the companies then discuss and analyse them. Based on the survey results, the managers of the Lufthansa Group, together with their teams, derive measures to improve the engagement index. The results are further analysed by management levels, functions and occupational groups to develop targeted measures.

As a result of the 2023 employee survey, for example, the Lufthansa Group defined core areas of action as a starting point for the follow-up process in the Group companies. The Group-wide cultural initiative, the Cultural Journey, was established as a shared area of action on this basis. The initiative promotes the individual identity of the Lufthansa Group companies with their diverse corporate cultures and simultaneously strengthens cultural understanding across the Group – with diversity forming a central pillar of our cultural identity.

Employee retention is encouraged through various initiatives, including the global Culture Community, which boasts over 2,000 voluntary members, or Culture Labs, where employees work in small groups to develop and implement culture-focused measures. Co-determination bodies are kept informed about the progress and outcomes of the Cultural Journey.

With regard to human rights compliance, employees of the Lufthansa Group Human Rights Office hold discussions with both their own employees and with employee representatives and networks. The Human Rights Office reports directly to the Head of Labor Relations Ground, Human Rights and Discrimination Prevention. They in turn report to the Chief Human Resources Officer of the Lufthansa Group. At least once a year, employees from the Human Rights Office and the works council enter into discussions. In addition, the Lufthansa Group Human Rights Office gains insights into the perspectives of the workforce through findings from human rights audits – especially when direct discussions take place with employees and the corresponding findings are then included in the audit report. Two audits were carried out in 2024. The focus was on South Africa and the DACH-B region (Germany, Austria, Switzerland and Belgium).

The Lufthansa Group evaluates the effectiveness of employee involvement by distributing a self-assessment questionnaire both before and after the launch of an engagement measure. If awareness of the human rights topics discussed increases, the engagement is considered effective. Such insights, together with the audit findings, are used in the risk analysis to further improve processes.

Employee retention is also reflected in exchanges between local employee representatives, the Human Resources department, and the central Human Rights Office responsible for the locations identified in the analysis. For example, these exchanges take place before the introduction of prevention measures or in order to assess the effectiveness of measures. It is the responsibility of the human rights coordinators at the Lufthansa Group to ensure that the described engagement takes place and that the results are incorporated into the Company’s risk management.

S1-3 – Processes to remediate negative impacts and channels for own workforce to raise concerns

The Lufthansa Group has established multiple whistleblowing channels for reporting concerns and potential violations.

Employees can raise issues regarding specific topics with their immediate supervisors or designated contacts. In addition, the Lufthansa Group has set up an electronic whistleblower system and an ombudsperson. Both are also publicly accessible to internal and external whistleblowers. The electronic Business Keeper Management System (BKMS) allows whistleblowers to submit reports in writing at any time, with the option to remain anonymous. The ombudsperson is an independent lawyer who is not employed by the Lufthansa Group. Reports can be submitted to the ombudsperson by phone, in writing or in person. Concerns related to discrimination, sexual harassment, human rights violations, or breaches of environmental laws can also be reported directly to the Human Rights Office.

Online and local communication campaigns further aim to improve the visibility of these whistleblowing channels. Networks of local contact persons further facilitate access for employees who prefer raising concerns through personal interaction.

Reports submitted to the Corporate Compliance Office or the Human Rights Office through these channels are first checked for plausibility and then classified into categories such as criminal offences or human rights violations. Depending on the topic, the reports are then forwarded to the designated Human Resources departments for further action. The processes for handling, monitoring and providing feedback to whistleblowers are defined in the respective process descriptions.

Employees who report unlawful or non-compliant behaviour, or who assist in investigations, are fully protected against any related personal disadvantage in accordance with applicable legal requirements.

S1-4 – Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

Comprehensive measures implemented under the Human Resources strategy

The Lufthansa Group develops and sets targets for its personnel measures in line with its Human Resources strategy, focusing on topics such as health and safety, adequate wages, work-life balance, occupational safety, a diverse workforce and human rights impacts.

Subsidiaries are largely free when it comes to incorporating the Group’s Human Resources strategy into operations and may tailor it individually based on their own strategies. Actions are developed at the Group level to achieve strategic objectives. Corresponding working groups are formed for this purpose. In Germany, measures affecting the Company’s own workforce are subject to co-determination requirements and must be presented to the relevant committees. The Human Resources Committee, which is made up of top-level personnel executives, labour directors and Human Resources managers from the individual subsidiaries, serves as the steering, decision-making and control body. The Lufthansa Group implements these measures using resources from the respective departments. Additional full-time capacity is provided when staffing needs increase.

The Lufthansa Group has developed measures derived from its Human Resources strategy to address the impacts, risks and opportunities of its business activities on its own workforce. These measures apply to all segments of the Lufthansa Group, although their geographic scope varies:

• Occupational medical care: The Lufthansa Group’s Medical Services offer employees the full range of occupational health care, adapted to their individual needs and taking their workplace and individual health conditions into account. The Medical Services also have outstanding expertise in aviation medicine and offer psychosocial advisory services.
• Geographic scope: Germany, Austria, Switzerland and Belgium
• Flu vaccinations: In October 2024, the Lufthansa Group offered flu vaccinations to employees in select countries.
  Geographic scope: Lufthansa Group locations in Germany, Austria and Switzerland
  
• Group-wide health management: Group-wide health management supports health managers in the individual companies. The Medical Operations Center (MOC) also offers wide-ranging support to Lufthansa Group passengers with pre-existing medical conditions or disabilities.
  Geographic scope: worldwide
  
• Partnership with a health insurer: In order to improve employee health, the Lufthansa Group’s health management in Germany entered into a partnership with a statutory health insurer during the reporting year, offering a wide range of workplace health management measures. Geographic scope:
  Lufthansa Group business entities in Europe
  
• Online training: In June 2024, the Group’s Occupational Safety department updated and modernised the mandatory online training for administrative roles.
  Geographic scope: Lufthansa Group in Germany
  
• Occupational safety survey: The Occupational Safety Department also launched a pilot project involving a self-assessment questionnaire on the topic of occupational safety in various areas of responsibility in 2024.
  Geographic scope: 13 subsidiaries during the pilot phase; subsequently worldwide
  
• New agreement on mobile working abroad within Europe: In 2024, the Cross-Border Work agreement was revised, allowing administrative employees to work remotely from abroad for up to 15 consecutive working days instead of the previous ten, with a number of limited exceptions.
  Geographic scope: Lufthansa Group in the European Union and Switzerland
  
• Female Leadership Programme: A programme for women in management roles was launched in 2022 to increase the proportion of female managers on the two hierarchical levels beneath the Executive Board.
  Geographic scope: Worldwide - Additional measures for female leadership: In order to increase the number of female international employees in the home markets (Germany, Austria, Switzerland, Belgium), a development programme and further initiatives were introduced in 2021.
  Geographic scope: Worldwide
  
• International Talent Programme: The Lufthansa Group aims to foster an inclusive culture based on intercultural understanding and appreciation while positioning the Company as an attractive destination for international talent. Since 2023, this includes a programme available to international talent who have not yet worked in one of the Company’s home markets (Germany, Austria, Switzerland, Belgium) but are interested in doing so. The programme prepares these individuals for the rotation and supports them throughout the entire process.
  Geographic scope: Worldwide
  
• Initiatives for Internationals: Since 2023, the Lufthansa Group has supported the integration of new international employees by offering networking events and an initiative in which colleagues in the home markets assist new foreign employees.
  Geographic scope: Worldwide
  
• Collective bargaining agreements: In 2024, the Lufthansa Group reached new collective bargaining agreements with the unions representing cockpit, cabin and ground staff. The agreements concluded guarantee a no-strike period of at least two years. Additions were also made to the existing collective agreements at Austrian Airlines, and collective pay increases were agreed for cockpit, cabin and ground staff. In Belgium too, collective agreements on pay increases were signed for all three professional groups at Brussels Airlines. A new collective agreement was signed with the trade union for cabin staff at SWISS in Switzerland.
  Geographic scope: Lufthansa Group in Germany; Passenger airlines in Austria, Belgium and Switzerland
  
• Expansion of the Code of Conduct: In February 2024, the Code of Conduct was updated to include a section on respectful behaviour. This is intended to emphasise the importance of combating discrimination and embed this principle across the Lufthansa Group.
  Geographic scope: Worldwide
  
• “Respect” – Anti-discrimination campaign: In 2024, the Lufthansa Group ran a Group-wide campaign against discrimination. The campaign aimed to raise awareness of various forms of discrimination, publicise reporting channels and complaint mechanisms and strengthen solidarity against discrimination.
  Geographic scope: Worldwide
  
• Complaint mechanisms: The Lufthansa Group also published additional information materials - including fact sheets and QR codes on business cards - to increase the visibility of existing complaint mechanisms.
  Geographic scope: Worldwide
  
• Training on human rights: In 2024, the Lufthansa Group has introduced new in-person and online training sessions to heighten workforce awareness of human rights and the handling of violations.
  Geographic scope: Worldwide

The Lufthansa Group intends to continue these measures into the near future. The Company aims to improve employee health and safety, enhance work-life balance, increase workforce diversity and improve working conditions and occupational safety. The measures are financed by the Lufthansa Group and are incorporated into the annual planning. The collective bargaining agreements have led to an approximate 7% increase in personnel costs.

Each measure is overseen by the relevant organisational units or divisional heads, who are responsible for implementation, monitoring and evaluating effectiveness. This includes ongoing reviews of existing measures to ensure continued impact. Key measures are approved and monitored by management. The strategy department tracks and assesses their effectiveness using performance indicators. In most cases, the Lufthansa Group has established qualitative targets for these measures. However, a specific quantitative target has been set for female leadership, with a goal to be achieved by 2025.