Lufthansa : Corporate Governance (241203 LH Code of Conduct EN)

Code of Conduct

OUR ETHICAL COMPASS

EN

»RESPONSIBLE AND LEGALLY COMPLIANT CONDUCT IS AN ESSENTIAL PART OF OUR CORPORATE CULTURE AND THE CORNERSTONE ON WHICH WE BASE OUR DAILY WORK.«

Responsible and legally compliant conduct is an essential part of our corporate culture and the cornerstone on which we base our daily work.

Dear Employees, dear Business Partners,

This Code of Conduct was adopted by the Executive Board as the foundation of our value system for the entire Lufthansa Group. It is binding for all employees of the Lufthansa Group. The Code of Conduct aims to strengthen our corporate culture and reinforce our commitment to ethics, integrity, and responsible conduct.

The principles set out in this document are not only the basis for fair competition, but also help us to identify and avoid legal and reputational risks. The Code of Conduct is a framework by which we align and measure our actions. It also helps us to make the right decisions and create a respectful working environment.

We are convinced that a company can only be sustainably successful if it is built on a foundation of trust, respect, and integrity. We therefore encourage you all to internalize the Code of Conduct and help make the Lufthansa Group a role model when it comes to ethical and responsible conduct.

Thank you very much for your support!

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CONTENTS

Introduction	4
About this Code of Conduct	4
We make responsible and well-considered decisions	4
We always openly address concerns	5
How we work together, how we lead	5
Responsibility for our society and our environment	6
Respectful treatment	7
Safety & Security	8
Climate and environmental protection	9
Respect for human rights	10
Occupational health and safety	11
Responsibility for acting with business integrity	12
Fair competition as the basis of our company's success	13
Combating corruption	14
Handling conflicts of interest	15
Compliance with foreign trade regulations	16
Prevention of money laundering	17
Digitization and data protection	18
Insider information and prohibition of insider trading	19
Transparent political lobbying	20
Responsibility for our company values	21
Proper accounting	22
Protection of our company resources	23
External communication in social networks	24

INTRODUCTION

About this Code of Conduct

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We make difficult decisions thoughtfully and responsibly

Despite all the rules and guidelines, there are sometimes gray areas where we do not immediately know how to act ethically and responsibly. Even this Code of Conduct cannot cover all conceivable critical situations. What often helps is our gut feeling: Do I have an intuitive feeling that something could be problematic? Would I rather discuss the matter with my superior?

The following steps can help you reach sound decisions in difficult situations:

Stop!

Before continuing your decision-making process, stop and take a moment to find out what is causing your uneasy feeling. Can you get more information to make your decision easier? Even if you may not be able to pinpoint the cause of your intuition, your feeling is important, and you should never ignore it.

Check!

Question your decision-making possibilities:

Why is the Code of Conduct important for us?

As employees of the Lufthansa Group, we are proud of our diver- sity, our individuality, and our respective personal and cultural backgrounds. In an increasingly fast-changing world, we use this Code of Conduct as a common guide to help us make decisions that are in line with the principles and values of our company. For our customers, business partners, and shareholders worldwide, the Code of Conduct describes what we, as one of the leading corporate groups in the aviation industry, stand for and what they can count on from us.

To whom does the Code of Conduct apply?

This Code of Conduct is binding for all Lufthansa Group employees worldwide, regardless of their function or hierarchy. Furthermore, the applicable laws, regulations, and internal rules and guidelines must be observed. Violations can lead to severe sanctions for the company and for individual employees.

Managers at all levels have a special responsibility to support their employees with their work in accordance with the principles described in this Code, and to always set an example of integrity and a sense of responsibility themselves.

Furthermore, this Code of Conduct defines what we expect from our business partners, including our suppliers. Our suppliers are additionally subject to the Lufthansa Group Supplier Code of Conduct, which builds on this Code of Conduct.

Who is responsible for updating this Code of Conduct?

The Lufthansa Group Chief Compliance Officer updates the Code of Conduct, which is then approved by the Executive Board.

• How would I act if I were only bound by my conscience?
• Am I being pressured into making a decision by something or someone?
• Would I have to worry if my conduct became public knowledge?
• What would my friends or family think of my conduct?

Act!

If you are sure that you are acting in accordance with the values and principles of the Lufthansa Group and all legal requirements, you can make your decision with a clear conscience.

If you have any doubts, ask your manager for support or contact your local Compliance Manager or the Corporate Compliance Office. Openly expressing concerns is not a sign of weakness or a lack of willingness to take risks, but an essential part of our speak-up culture.

We always openly address concerns

On the ground and in the air

In the aviation industry, open communication that does not depend on hierarchy or seniority is crucial for safety. For us as the Lufthansa Group, this principle naturally also applies to all other business segments. We openly address questions, uncertainties, concerns, or even just a gut feeling that something is wrong. This requires courage, but it is the only way to identify potential violations of laws or internal regulations at an early stage and take remedial action.

Reporting options

If you become aware of a possible violation, you have various options for reporting it:

• Talk to your manager,
• ask your local Compliance Manager,
• contact the Corporate Compliance Office,
• use the electronic whistleblowing system, or
• contact our ombudsperson, who is an external lawyer.

There may also be additional reporting channels or contact persons depending on the company and topic.

You can remain anonymous if you wish

A report can also be made completely anonymously via the electronic whistleblowing system and the ombudsperson.

Don't be afraid of consequences!

Our cooperation is based on mutual trust. Perhaps you are afraid of negative consequences if you report a hint, or you may not be sure whether your suspicion is actually a compliance violation.

You may be thinking about ignoring your uneasy feeling, or you may be trying to convince yourself that everything will be fine.

The Lufthansa Group is committed to the legal requirements for the protection of whistleblowers from all reprisals and disadvantages that could be threatened as the result of a report (Non-Retaliation Policy). In particular, this includes unequal treatment, termination of employment, denial of a promotion, or submission of a negative assessment. Intimidation and attempts at unequal treatment are prohibited.

Violations of the Non-Retaliation Policy, the confidentiality requirement and willful obstruction of the submission of reports will be prosecuted and sanctioned. This protection only ceases to apply if the whistleblower can be proven to have deliberately misused the whistleblowing system by providing false information.

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How we work together, how we lead

Our corporate culture integrates the interests and needs of customers, employees, and stakeholders in equal measure. It is therefore our compass for ethical behavior, acceptance of responsibility, and trusting cooperation as the basis for our economic success. Our managers act as role models and provide employees with the opportunity to develop continuously. Above all, it is their task to firmly establish the values of the Lufthansa Group in our culture.

Our corporate values of Ambition, Responsibility, and Empathy are the cultural guidelines for our management and collaboration:

Ambition:

• We put the customer at the center of everything we do.
• We do not wait for perfect solutions before we make decisions.

▪ We are innovative and are constantly looking for ways to improve.

Responsibility:

• We keep an eye on the short- and long-term consequences of our actions.
• We take responsibility for our actions, learn openly from mistakes, and avoid apportioning blame.

▪ We take action to overcome our challenges without needing to be asked to do so.

Empathy:

• We respect and integrate different points of view.
• We talk to each other honestly, even if it is not always easy.
• We support and recognize each other to achieve common goals.
• We are guided by competencies derived from these values when selecting and developing managers and assessing potential.

RESPONSIBILITY FOR OUR SOCIETY AND OUR ENVIRONMENT

Respectful treatment

We treat our colleagues and external stakeholders with respect. We are opposed to any form of discrimination, harassment, or violence.

Our goal is to connect people and cultures. Our actions are therefore characterized by the appreciation of people regardless of national and ethnic origin, gender, religion, ideology, disability, age, or sexual identity. We consistently oppose discrimination of this kind and we expect the same conduct from our business partners and suppliers.

Why do we have this rule?

We value interaction that is free of discrimination and which respects personal boundaries. If employees, customers, suppliers, or business partners find themselves in intimidating or cross- border situations, they can rely on our support and a confidential setting for discussion.

Lufthansa has zero tolerance for cases of sexual harassment, because it is clear: Any case is one too many and there is no justification for sexual harassment.

Ask yourself:

• How can I help promote respectful behavior in my working environment - towards colleagues and external stakeholders?
• Do I clearly set my boundaries and do I respect the boundaries of others?
• Could the way I communicate, or the content of what I say, or my behavior be perceived as derogatory, discriminatory, or harassing?
• Am I possibly unaware of my bias?
• Do I encourage individuals to make an official report of an incident?

References:

Lufthansa Group Website > Investor Relations > Corporate Governance & Compliance > Compliance > Whistleblowing System

Further information is available at:

[e-mail]

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Example:

Question: During the break, I notice that a colleague is showing his nude beach vacation photos to a female colleague without being asked. She is visibly uncomfortable with the situation and is trying not to look. What is the right thing to do?

Answer: The Lufthansa Group has zero tolerance for sexual harassment. It is often difficult for victims of sexual harassment to take the initiative and defend themselves. You can support the people concerned by listening to them and providing advice. Encourage the person concerned to officially report the incident. Because one thing is certain: Sexual harassment can never be justified.

Example:

Question: After training for a new position, I realize that I have made a mistake in an important process. Should I solve the problem short- term and hope that it only happened to me?

Answer: No, use the existing reporting channels for safety and security incidents to draw attention to the problem. We can then work together to identify and analyze the causes so we can help our colleagues make the right decisions in the future. This is how we continuously develop our safety standards.

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Safety & Security

We guarantee the highest safety standards and do not tolerate any compromises when it comes to safety and security.

"Safety" describes the active minimization of flight risks arising from our operations. "Security", on the other hand, describes measures to protect our employees, passengers, and property from external threats.

Why do we have this rule?

A large number of people and business partners around the world make use of our services every day. They count on us to maintain our safety standards at the highest level. This is our responsibility. Our safety culture and our security and safety management system ensure that we continuously work on our high standards and live up to this responsibility.

Ask yourself:

• Am I aware that my personal vigilance in safety and security is of great importance for the safety of our company and our customers?
• In stressful situations, do I ever feel that I cannot fully comply with safety or security requirements?
• Am I sufficiently aware of the security requirements in our company?
• Do I actively address potential safety or security incidents and breaches?
• Do I know how to report safety or security incidents immediately?

References:

• Group Guidelines for Safety and Security
• Specifications of the Lufthansa Group Safety Management System (SMS) as well as of the Security Management System (SeMS)

If you have any questions, please contact:

• Corporate Security & Crisis Management FRA CS
• 24/7 Security Desk
• Office of the Group safety pilot FRA CF

Climate and environmental protection

We take responsibility for our environment and our impact on it.

Relevant environmental aspects involve our direct and indirect consumption of resources (e.g. energy, water, raw materials) and the associated impact on ecosystem services such as the climate, greenhouse gas emissions, and biodiversity.

Why do we have this rule?

Continuously reducing these effects supports the future viability of our business model, helps us with our transformation processes, and strengthens our competitiveness. We follow the precautionary principle and consider potential risks and opportunities, take initiatives to promote environmental awareness, and accelerate the development and dissemination of environmentally friendly technologies.

We set ourselves ambitious targets and substantiate them with measures that contribute to a continuous and measurable improvement in our environmental performance. The Lufthansa Group's environmental guidelines describe how we see ourselves in terms of environmental protection and they form the basis of our actions.

Ask yourself:

• Do my actions comply with environmental protection laws and regulations?
• How will my current actions and decisions affect the climate and the environment?

References:

• Environmental Guidelines of the Lufthansa Group
• Lufthansa Group Website > Responsibility

Further information is available at:

Corporate Responsibility

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Example:

Question: I mainly work in the office - what can I do specifically to protect the environment?

Answer: Quite a lot - here are just a few examples: Take environmental aspects into account in your decision if you can influence them. Check what other decisions you can influence at your workplace or through your work. Include the topic of environmental protection in your regular team meetings - this is often where good ideas and measures are developed. Print on paper only if necessary and also on both sides. Switch off the lights and the monitor when you leave your office. Undoubtedly, you can think of many more possibilities as you go about your day-to-day work.

Example:

Questions: One of our suppliers receives supplies from company A, with which there are no other contractual relationships. I have learned that employees at company A are working under undignified and inhumane conditions. Can I continue to do business with our supplier as before?

Answer: No. Because of your knowledge of actual indicators that suggest a possible violation of human rights, measures must be initiated. In such a case, please contact the Human Rights Office.

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Respect for human rights

We want to promote human rights worldwide. We aim to anchor this expectation in the companies of the Lufthansa Group and their supply chain.

Human rights include, in particular, prohibition of both child and forced labor and slavery, compliance with occupational health and safety obligations, respect for freedom of association, working conditions that are adequate and humane, and refraining from environmental pollution, land deprivation, torture and cruel, inhuman or degrading treatment.

Why do we have this rule?

For the Lufthansa Group, as a member of the UN Global Compact and signatory to the International Air Transport Association's (IATA) resolution against human trafficking, it is important to bring our actions in line with recognized international labor and social standards and to actively establish a firm respect for human rights in our day-to-day business.

Ask yourself:

• Does my working environment comply with applicable human rights regulations and recognized international labor and social standards?
• Am I familiar with the protected legal positions and complaint channels?
• Have I informed our suppliers and other business partners of our expectations regarding compliance with these standards?

References:

• Lufthansa Group Website > Investor Relations > Corporate Governance & Compliance > Compliance > Whistleblowing System
• Lufthansa Group Website > Corporate Responsibility > Ethics and Integrity > Modern Slavery and Human Trafficking Statement

If you have any questions, please contact:

[e-mail]