Impact, risk and opportunity management

S1-1 – Policies related to own workforce

The Lufthansa Group uses a proven HR strategy with clear priorities

Megatrends such as demographic change, particularly in Europe, increasing individualisation and pervasive digitalisation present significant challenges and opportunities for the Lufthansa Group. They underscore the need for the Lufthansa Group to maintain a sustained high level of capacity for transformation and adaptation.

The Lufthansa Group HR 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 HR 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 implementing the strategy.

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

The Lufthansa Group’s policy statement on the German Supply Chain Due Diligence Act (LkSG) from 2023, updated in November 2025, outlines its human rights strategy. It also sets out how the Lufthansa Group fulfils its due diligence requirements, which human rights and environmental impacts have been identified as high priorities on the basis of the analysis, and which human rights and environmental expectations apply to the employees and suppliers of the Lufthansa Group. ↗ 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 preventive 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 works councils, 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 the person responsible for a violation is unable to immediately cease, prevent or minimise a breach, the Lufthansa Group will develop and implement a corresponding remedial and/or prevention plan. This also applies in cases where violations are caused by individuals who are not directly employed by the Lufthansa Group but act on behalf of service providers. In such cases, a range of measures may be considered, including the joint development and implementation of a plan with the responsible company to eliminate or reduce the breach, as well as 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 Supply Chain 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 (ICESCR),
the four core labour standards of the International Labour 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 International Air Transport Association (IATA) Resolution against Trafficking in Persons, and
environmental agreements such as the Minamata Convention on Mercury, the Stockholm Convention on Persistent Organic Pollutants and the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal.

The Lufthansa Group’s Code of Conduct supports 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 groups in the aviation sector. 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 health and safety, anti-corruption measures, handling conflicts of interest, digitalisation and data protection, and external communication in 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 subjects of complaints regulated in this document include discrimination in the workplace. The aim of the complaints procedure is to obtain information on human rights or environmental risks within the Lufthansa Group and its suppliers at the earliest possible stage to ensure measures can be taken 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 corporate occupational safety policy protects health

The globally applicable Lufthansa Group occupational safety policy 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 in accordance with the German Occupational Safety and Health Act. The policy covers occupational safety regulations, outlines responsibilities, describes the organisational structure of the occupational safety function, and defines escalation levels and approval requirements.

The effectiveness of the policy 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 policy.

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. Responsibility for the correct implementation of this group works agreement lies with the Labor Relations and HR Policies department, which reports directly to the Chief Officer Human Resources and Legal Officer.

Life-phase-oriented HR policy as part of sustainable value creation

The Lufthansa Group has embedded the reconciliation of professional requirements with individual life circumstances as a core element of its HR strategy. The aim is to provide tangible relief for employees in different life phases and to offer reliable frameworks that support both their private and professional lives. Through offerings such as company-supported childcare and care services, the Company seeks to increase employees’ personal capacity to act and to help alleviate stressful situations at an early stage. This strategic focus underscores the Lufthansa Group’s commitment to sustainable value creation that aims to ensure the long-term employability and wellbeing of its employees.

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!”. The Employee Feedback and Performance Management department, which is part of the Chief Human Resources and Legal Officer’s division, is responsible for this operational process. The survey alternates between a full survey and a shortened version every two years. It 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. The survey measures, among other things, 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 2025. The results of the engagement index are measured on a scale from 5 (best) to 1 (worst). The Company exceeded its target benchmark value of 3.6, reaching 3.9 in 2025. Across the entire Lufthansa Group, the engagement index is 0.1 points higher than in the previous year’s survey.

The results of “involve me!” are presented to the Executive Board and Supervisory Board of the Lufthansa Group. The management teams of the individual companies then discuss and analyse the results. Based on the survey results, the managers of the Lufthansa Group, together with their teams, derive measures to further improve the engagement index. The results are also analysed and evaluated by management levels, functions and occupational groups in order to identify specific areas for action and develop targeted measures.

Based on the results of the 2023 employee survey, the cultural initiative “Cultural Journey” was defined as a shared area of action and subsequently established within the organisation. The initiative reports directly to the Chairman of the Executive Board and is managed by the Culture and Executive Program department. The Cultural Journey aims to promote the individual identity of the different Lufthansa Group companies and simultaneously strengthen a shared cultural understanding across the Group – with diversity forming a central pillar of our cultural identity.

Drawing on the results of the 2024 employee survey, core areas of action were once again identified and, in 2025, incorporated into the measures of the cultural initiative. In particular, the focus of the initiative was placed on the themes of feedback, psychological safety, decision-making and health. These focus areas are intended to promote open dialogue, mutual trust and a healthy and sustainable leadership culture within the Lufthansa Group.

To implement the measures derived from the employee survey results, a range of activities were offered and delivered in the reporting year, including workshops on feedback culture and psychological safety. The concept of psychological safety aims to strengthen trust, inclusion and participation within a team or group. Employees from various areas of the Lufthansa Group were trained in these workshops to act as multipliers for psychological safety and to disseminate understanding of the concept across the Group. In addition, a Group-wide podcast entitled “Voices of Vielfalt” (“voices of diversity”) was established. It discusses and examines how today’s rapidly changing world is affecting corporate cultures and how they need to evolve in order to meet upcoming challenges. A total of eight episodes were released in 2025. Health-related action days were also organised, during which employees were provided with practical tips, inspiring ideas and useful information on nutrition, physical activity and mental resilience.

These activities are intended to underscore the Lufthansa Group’s commitment to actively involving employees and to embedding cultural development as an integral component of responsible corporate governance. Co-determination bodies are kept informed about the progress and outcomes of the Cultural Journey.

In the area of human rights, the Lufthansa Group Human Rights Office holds discussions with its own employees, for example as part of audits or on specific occasions, as well as with employee representatives and internal network groups such as “CourageUp” and “BiasFighters”. The Human Rights Office reports directly to the Head of Labor Relations and HR Policies. They in turn report to the Chief Human Resources Officer of the Lufthansa Group. At least once a year, an exchange takes place between the Human Rights Office and the works council. The Human Rights Office also 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. Three audits were conducted (previous year: two) in 2025. The audits focused on the implementation of human rights obligations in the North America region and in global procurement. The adequacy of human rights risk management was also subject to review.

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 engagement 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. These exchanges take place before the introduction of prevention measures or in order to assess the effectiveness of measures, for example. 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. The Human Rights Officer and Internal Audit department of the Lufthansa Group conduct the review of the complaints procedure’s effectiveness. To promote the involvement of target groups and stakeholders, employees are informed about the Lufthansa Group’s complaint channels via the intranet. The involvement of stakeholders such as works councils and trade unions also represents a way to incorporate the interests of workers in the value chain.

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 mitigating 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 and implemented 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.

Measures relating to employee health and sustainable employability

Comprehensive occupational medical care: The Lufthansa Group’s Medical Services offer employees 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
Group-wide health management: Group-wide health management supports health managers in the individual companies. The Medical Operations Center (MOC) also offers support to Lufthansa Group passengers with pre-existing medical conditions or disabilities.
Geographic scope: worldwide
Annual flu vaccinations: In October and November 2025, flu vaccinations were offered to all Lufthansa Group employees.
Geographic scope: Germany, Austria and Switzerland
Communication on the 2025 health calendar: The Lufthansa Group Health Hub communicated monthly focus topics and organised health-related action days for all Lufthansa Group employees. The objective was to support employees in maintaining, improving and restoring their health through personal responsibility.
Geographic scope: worldwide
Introduction of a nutritional traffic-light system: To promote healthy eating, a standardised visual labelling system for meals was introduced in 2025 in Lufthansa Group staff restaurants in Germany. The system allows employees to quickly and clearly assess the nutritional profile of the dishes on offer. Key indicators such as fat and sugar content, as well as preparation methods, are visible at a glance, supporting informed choices and a healthy, balanced diet.
Geographic scope: Lufthansa Group staff restaurants in Germany
Partnership with a health insurer: In order to improve employee health, the Lufthansa Group’s health management in Germany continued its existing partnership with a statutory health insurer during the reporting year. The cooperation aims to support employee health on a long-term basis. It ensures the ongoing availability of occupational health management measures, including initiatives related to physical activity, nutrition and resilience.
Geographic scope: Lufthansa Group business entities in Germany

Measures related to occupational safety

Occupational safety survey: Building on the pilot project conducted in the previous year, a Group-wide occupational safety self-assessment survey was rolled out worldwide in 2025. The objective is to obtain a comprehensive overview of the current status of occupational safety and the implementation of the occupational health and safety management system across the Group. All Group companies with at least 20 employees were included in the survey.
Geographic scope: worldwide
Occupational safety audits: External occupational safety audits were commissioned and carried out at selected Group companies. The selection was based on the results of the self-assessment. Criteria included elevated accident rates and the occurrence of serious workplace accidents. The audits, conducted by an external service provider, assessed compliance with country-specific statutory occupational health and safety requirements. In addition, selected internal minimum standards of the Lufthansa Group were audited.
Geographic scope: worldwide
Introduction of minimum standards for external contractor coordination: In September 2025, the Group Occupational Safety department developed and implemented a Group-wide minimum standard for the coordination of external contractors. The standard defines requirements for coordinating contractor activities, irrespective of their type, duration or scope, and regulates cooperation between Lufthansa Group companies and external contractors from an occupational health and safety perspective.
Geographic scope: worldwide

Measure relating to adequate pay

Continued validity of collective bargaining agreements: In 2024, the Lufthansa Group reached new collective wage 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

Measures relating to work-life balance

Extension of company-supported childcare provision: At its hubs in Frankfurt and Munich, the Lufthansa Group provides company-supported childcare places to support employees with children.
Geographic scope: Frankfurt and Munich sites
Family service portal: The family service portal provides access to a wide range of support services, including help with finding childcare providers through ad hoc and regular childcare arrangements, as well as parent-and-child offices at selected sites that can be used if a need arises at short notice.
Geographic scope: Germany
Support services for employees caring for family members: Since January 2025, additional formats and advisory services have been available to employees via the CareBenefit service portal. These services are designed to ease everyday burdens and support employees in reconciling work with family caregiving responsibilities. They include, for example, individual consultations on topics such as advance care planning documents and care benefits, as well as access to digital tools such as a care level calculator.
Geographic scope: Germany
Conclusion of “Tarifvertrag Teilzeit Nummer 3”: In 2025, a new part-time collective bargaining agreement (no. 3) was concluded for cabin crew employees at Lufthansa Airlines. The agreement aims to support cabin crew in achieving more reliable planning and a better balance between professional and private life, while also enabling Lufthansa Airlines to pursue long-term, demand-oriented workforce planning for part-time employees.
Geographic scope: Germany

Company

Combined management report

Consolidated financial statements

Remuneration report

Further Information