The German Stock Corporation Act and the German Corporate Governance Code are key elements on which it is based. Our declaration of conformity pursuant to the German Corpo- rate Governance Code may be found on page 17 of the 2013 Annual Report. Lufthansa is also registered in the voluntary transparency register of the European Com- mission and European Parliament. The goal of this public register, which was set up in June 2011, is to increase the transparency of deci- sion-making processes within the EU and to ensure that interactions between EU institu- tions and organizations, associations and companies are in conformity with current law and are conducted on the basis of ethical principles. Ú The Lufthansa Compli- ance Program ensures compliance with appli- cable law Compliance refers to all measures taken to ensure that companies, their executive bod- ies, and their employees observe the law in their conduct. The Lufthansa Compliance Program, which was established in 2004, is intended to keep employees from violating the law and to train them in the application and interpretation of legal norms. As an aviation company with global operations, the Lufthansa Group advocates fair competition, integrity, and responsible action. The compli- ance guidelines are in unison with the Lufthansa Group’s existing guidelines, pro- grams, and work rules. Organization of the Compliance Program The Compliance Office, which was estab- lished on October 1, 2007 within the central legal department, is responsible for imple- menting, developing, and communicating the Lufthansa Compliance Program. In addition, the various Group companies have appointed Compliance Commissioners and Compliance Managers. The Compliance Office coordi- nates investigations into circumstances sur- rounding compliance issues and serves as a contact point for antitrust and investigative authorities, to which Lufthansa gives its full cooperation. The compliance guidelines constitute a core component of the Lufthansa Compliance Program. These internal regula- tions mark out for employees the limits of proper practice to ensure that conduct con- forms to a uniform and legally compliant standard. The company is not willing to toler- ate any violations of law by its employees. Culpability for violations of law has legal consequences under labor law and may also entail personal liability. The Lufthansa Compli- ance Program currently comprises modules relating to competition, capital market, integ- rity, embargo, and corporate compliance matters. Competition Compliance The Competition Compliance module familiar- izes employees with the relevant provisions of antitrust legislation to minimize or exclude the risks Lufthansa faces under antitrust law. All employees who are exposed to matters in which antitrust law is of relevance are trained in the fundamental provisions of European and national antitrust legislation. Capital Market Compliance The Capital Market Compliance module gives employees an overview of the applicable provisions of capital market law, such as those concerning insider trading or ad hoc publicity. In this way, and with an accompany- ing training program, all employees and company bodies concerned receive an in- depth understanding of the provisions of the German Securities Trading Act (Wertpapier- handelsgesetz). Integrity Compliance With the Integrity Compliance module, Lufthansa documents its fundamental approach to legal compliance in its business dealings. The duty to conduct oneself in a Corporate governance and compliance For the Lufthansa Group, corporate governance is expressed in practice as corporate management and control that is informed by an awareness of the company’s responsibilities and aimed towards sustainable value creation. It meets high international standards and is of central importance in our efforts to maintain transparency towards the shareholders and continually increase trust in the company’s management. 28 // Sustainable Business Practice