Metrics and targets

G1-4 – Incidents of corruption or bribery

In 2025, there were zero convictions (previous year: zero) and EUR 0 (previous year: 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. If an investigation should confirm a violation of applicable anti-corruption or anti-bribery regulations, the Lufthansa Group will take appropriate individual actions, taking into account the individual circumstances of each case. This may consist of disciplinary action, claims for damages, increased training and awareness 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 topics of the Lufthansa Group that are subject to its lobbying activities and are updated quarterly in the lobbying register of the German Bundestag (Federal Parliament):

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. In particular, this includes the definition of extraordinary circumstances and the adjustment of delay thresholds.

Financing of SAF quota through uniform levy

The Lufthansa Group advocates 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.

Expansion of free SAF certificates

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

Introduction of European support strategy for SAF

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

Introduction of 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.

Introduction of single European airspace

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

Maintaining advance payment practice

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

Making 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.

Maintaining European regulation on common rules for slot allocation at airports

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

Creation of 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 screenings and moving forward with certification.

Revision of EU Regulation 1069/2009 (hygiene 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.

Maintaining 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 across Europe.

Connecting 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.

Application of Carbon Border Adjustment Mechanism (CBAM) in aviation

The Lufthansa Group advocates applying this CO₂ border adjustment system, as part of EU climate policy, to non-European airlines.

Introduction of prioritised air traffic control clearances

The Lufthansa Group advocates inserting a legal basis for granting prioritised air traffic control clearances according to the BEBS principle into the air traffic control implementation regulation.

No introduction of a kerosene tax

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

Inclusion of aviation in German carbon management strategy

The Lufthansa Group advocates the inclusion of aviation in legislation enabling carbon capture and storage (CCS) and carbon capture and utilization (CCU).

Closure of EU legislative gaps in working conditions

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

Reforming strike law

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

Making employment references transmittable in text form

The Lufthansa Group advocates adapting the German Industrial Code to allow employment references to be transmitted in text form (instead of exclusively in written form).

Introduction of weekly working hours

The Lufthansa Group advocates changing the definition of working hours so that these are now counted on a weekly basis rather than a daily basis.

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

The Lufthansa Group advocates for reporting obligations within the scope of the implementation of the EU Pay Transparency Directive to be implemented unbureaucratically and for privileges to be created for collective bargaining parties.

Privileged treatment of 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.

Transposition of 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 due to state fees

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

Checking of biometric data in passengers’ passports for their identification

The Lufthansa Group advocates legislation permitting checking of the biometric data in passengers’ passports for the purpose of their identification when using aviation services.

Adjustment of the flight restriction rule for airlines with a risk management process

The Lufthansa Group advocates exemptions from the flight restriction rule under the German Aviation Control Act for airlines with a risk management process.

Recognition of existing protective restrictions in terms of critical infrastructure (KRITIS)

The Lufthansa Group advocates recognition of existing KRITIS-related protective restrictions for companies and coherent (implementation) legislation in this area.

Recognition of safety standards in the aviation sector

The Lufthansa Group advocates reciprocal recognition of aviation safety standards at the European level.

Appropriate restrictions on liquids in the context of airport security checks

The Lufthansa Group advocates appropriate restrictions on liquids in the context of airport security checks and the maintenance of these restrictions. This includes, in particular, where liquids are carried in hand luggage and the existing easing of rules relating to liquid limits.

Consideration of the current state of technology in regard to regulation of baggage unloading

The Lufthansa Group advocates consideration of the latest technological standards in relation to the regulation of baggage unloading using new control technology.

Continued reciprocal recognition of air safety inspections in the EU

The Lufthansa Group advocates continued reciprocal recognition of air safety inspections in the EU.

Introduction of a uniform EU reporting system for air safety occurrences

The Lufthansa Group advocates the introduction of a uniform reporting system for air safety occurrences in the EU.

Risk-based statutory requirements in relation to airport security measures

The Lufthansa Group advocates risk-based statutory requirements in relation to airport security measures and stronger deterrents (criminal prosecution, advance identification, longer sentences).

Compensation for competitive disadvantages as a result of sanctions

In response to war-related airspace closures, the Lufthansa Group advocates for uniform conditions to be established in the international competitive environment, by means of either financial or air traffic measures.

Reform of the Green Deal

The Lufthansa Group advocates the rapid revision of climate policy regulations which, in the main, only affect EU companies, so as to establish competitive neutrality.

Suspension of the air traffic agreement with Qatar

The Lufthansa Group advocates the suspension of the air traffic agreement with Qatar.

Revision of the Aviation Personnel Ordinance (LuftPersV) in line with European practice

The Lufthansa Group advocates the replacement of the licensing obligation for engine and air safety equipment personnel entitled to grant approvals with internal authorisation concepts agreed with the German Federal Aviation Office.

Promotion of test flights for climate research

The Lufthansa Group advocates state funding of test flights to research climate impacts.

Revision of the ban on provision under Article 3(2) of Regulation (EU) 2023/1529

The Lufthansa Group advocates the revision of the ban on provision under Article 3(2) of Regulation (EU) 2023/1529 for ground handling services so that these remain usable.

Registration of the Lufthansa Group in transparency registers

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
• Austrian Airlines, EU Transparency Register 983474516327-48

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 prior to their appointment during the current reporting period:

• Tom Benedict
• Alexander Holzrichter
• Anna Maaßen
• Jim Würz

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 complies with national legislation and regulations, which specifically prescribe standard payment deadlines. The Lufthansa Group’s standard payment deadlines are 30, 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 51 days (previous year: 41 days).

The payment deadlines agreed with suppliers apply for incoming invoices. In case of a discrepancy between the payment deadlines agreed in an order, the payment deadlines registered in the master data, contractually agreed payment deadlines or the payment deadlines indicated on an invoice, as a rule the payment deadlines which are more advantageous for the Lufthansa Group will be selected. Furthermore, timely payment (on the basis of the payment deadlines applied) is a control indicator with a target of 92%, based on the number of incoming invoices.

The Lufthansa Group monitors payment outflows and thus the time until settlement of an invoice Group-wide through system reports on a monthly basis. Several times a year, the results are exchanged with the Lufthansa Group’s business units in 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. 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.

The current number of pending legal proceedings for late payment is two (previous year: zero) for the year 2025 at the Lufthansa Group.