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ePaper created 2014-08-08, 11:09:35 | version 1.32.01
manner that is free of corruption and ethically correct flows naturally from current law, inter- nal compliance guidelines, and the commit- ments Lufthansa has made through its membership in the relevant national and international organizations. Examples include the Lufthansa Group’s commitment to the principles of the UN Global Compact and its membership in Transparency International. The Integrity Compliance guidelines and checklist provide guidance on how to handle invitations, gifts, and other considerations. Corporate Compliance The Corporate Compliance module bundles those internal regulations that are of key importance for the Lufthansa Group from a legal standpoint and makes them transparent for employees. Embargo Compliance The Embargo Compliance module serves to ensure compliance by the Lufthansa Group, as a globally operating group of companies, with the provisions of foreign trade sanctions imposed against specific countries or per- sons. The Embargo Compliance guidelines mark out for the employees concerned the limits of proper practice. Regular training in matters of compliance Automated IT processes ensure that all employees and executive bodies at Lufthansa participate once a year in the web-based training courses (e-learning courses) that are relevant to what they do. Employees of the subsidiaries also have access to these e-learning courses and are to some extent already included in the automated mailing list. The Compliance Office regularly offers face- to-face training courses as well. Compliance training is an integral part of leadership semi- nars, management courses, and other internal continuing education events and conferences. Monitoring and reporting Self-audits and external audits ensure that the Compliance Program is implemented effectively in light of the current require- ments under the Accounting Law Modern- ization Act (Bilanzmodernisierungsgesetz). In addition, the Supervisory Board’s Audit Committee is informed twice a year of cur- rent compliance-related developments within the Group and the current state of the program’s implementation. ß The Lufthansa Compliance Program Program consisting of five modules The Compliance Office is responsible for implementation, development, and communication Competition Capital Market Integrity Embargo Corporate Ombudsman system Ú Another fundamental element in the Lufthansa Compliance Program is the ombudsman system, a pro- gram of proven effectiveness that has been implemented worldwide. Introduced on December 1, 2007, it serves as an additional preventive measure against white-collar crime. An ombudsman outside the com- pany can receive information from employees or third parties by tele- phone, in writing, or in person. The office of ombudsman is performed by Dr. Rainer Buchert, a Frankfurt lawyer who is subject in full to the legal duty of professional secrecy and who also has the right to refuse to give evidence to govern- ment investigative authorities. The ombudsman refers all information given to him to Lufthansa without disclosing the names or identities of his informants. Disclosure of an informant’s identity to Lufthansa or third parties without the informant’s consent is prohibited. Sustainability Report Balance // Issue 2014 // Lufthansa Group // 29