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abiding conduct across the Group. The Lufthansa Group is not willing to tolerate violations of law on the part of its employ- ees. The Group Compliance Of ce coordi- nates the investigation of circumstances relevant to compliance and in this context serves as a contact point for cartel and investigative authorities, with whom the Lufthansa Group cooperates without reser- vation. Culpable breaches of law lead to consequences under labor law and may also entail personal liability. Competition Compliance The module Competition Compliance introduces employees to the relevant regu- lations of competition and cartel legislation, so as to minimize or exclude risks for the Lufthansa Group. All employees handling issues relevant to competition or cartels are trained in the fundamental regulations of German and European antitrust legislation. Integrity Compliance With the module Integrity Compliance, the Lufthansa Group documents its fundamen- tal approach of law-abiding conduct in business relationships. The obligation to adhere to non-corrupt and ethically correct conduct ow naturally from current law, the internal Compliance Guidelines and the Group’s memberships in relevant national and international organizations. Examples of the latter include the Lufthansa Group’s commitment to the principles of the UN Global Compact (see page 27) and its membership in Transparency International. The Integrity Compliance Guidelines pro- vide support in handling invitations, gifts and other attentions. Capital Market Compliance The module Capital Market Compliance gives employees an overview of current capital market law, such as regulations relating to insider trading or ad hoc publi- city. Accompanied by specialized training, this module ensures that all employees and Company bodies concerned receive in- depth insight into the regulations of the German Securities Trading Act (WpHG). Embargo Compliance The module Embargo Compliance serves to ensure that the Lufthansa Group, as a globally active corporation, adheres to country- and person-speci c sanctions and regulations in the area of foreign trade. The Embargo Compliance Guidelines provide the employees concerned with a binding framework of conduct. Compliance training Automated IT processes ensure that all employees participate regularly in those Web-based Compliance trainings that are relevant for them. The employees of the subsidiary companies also have access to these e-Learning courses and are either included in automatic mailings of materials or have their own company-speci c pro- cesses. In addition, the Group Compliance Of ce conducts trainings with personal participation worldwide and offers work- shops. Third-party due diligence processes The Lufthansa Group expects compliance from its business partners as well. Based on risk, business partners are therefore screened by means of third-party due diligence processes before the beginning of a business relationship. Monitoring and reporting In keeping with current requirements in the framework of the German Accounting Law Modernization Act, self-audits and external audits take place to evaluate the effective implementation of the Compliance Program. Furthermore, the Supervisory Board’s Audit Committee is informed twice a year about current developments relevant to com- pliance issues and the current state of the program’s implementation within the Group. Ombudsman system A further basic component of the Lufthansa Compliance Program is the globally imple- mented and proven ombudsman system, which also allows anonymous information concerning possible breaches of compli- ance. Introduced on December 1, 2007, it serves as an additional preventive measure against economic crimes. Relevant infor- mation can be given by employees or by third parties to an ombudsman outside the Company, by telephone, in writing or in person. The ombudsman function is ful- lled by Frankfurt-based lawyer Dr. Rainer Buchert, who is fully bound by the profes- sional obligation of secrecy and also has the legal right to refuse to give evidence to public investigative authorities. The ombuds- man communicates any information he receives to Lufthansa while respecting absolute con dentiality concerning the name and identity of the informant. In this way, the disclosure of an informant’s iden- tity to Lufthansa or to third parties without his or her consent is ruled out. Furthermore, Lufthansa is listed in the joint transparency register of the European Commission and the European Parliament. The goal of this public register is to increase the transparency of decision-making pro- cesses within the EU on a voluntary basis and to ensure that the interactions between EU institutions and organizations, associa- tions or companies are in conformity with current law and are carried out on the basis of ethical principles. 26 // Sustainable Business Practices

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