Comprehensive programme helps to ensure compliance
Compliance describes all measures taken to ensure the correct conduct of companies, their management and staff with respect to statutory and the Company's own obligations and prohibitions. The Lufthansa Group Compliance Programme is intended to prevent staff and the Company from coming into conflict with the law and at the same time to help them to apply statutory regulations correctly.
The Lufthansa Compliance Programme is made up of the following elements: Competition, Capital Markets, Integrity and Embargo Compliance. An ombudsman system gives staff the opportunity to report any suspicion of criminal activity or breaches of the compliance regulations. The Corporate Compliance Office, which reports to the Board member responsible for Human Resources and Legal, further develops the Compliance Programme conceptually and provides trainings (eLearning and classroom trainings). The Organisation using central and (optional) local compliance committees, as well as appointing compliance managers in the entire Lufthansa Group ensures the involvement of the responsible employees and builds awareness of the Compliance Programme. The Audit Committee of the Supervisory Board is notified semi-annually of incidents and progress concerning compliance in a Compliance Report.
The Ombudsman is a freelance attorney who is not an employee of the Lufthansa Group. As a neutral, independent contact, the Ombudsman takes complaints in writing or by telephone and provides them to the Corporate Compliance Office in an anonymized form, if this is what the complainant wishes. The identity of the complainant is protected by attorney-client privilege. Moreover, the Lufthansa Group has contractually agreed not to request access to any legally privileged information and to be informed of the complainants´ name only following his/her express consent.