Balance 2015 ENG

Compliance training Automated IT processes ensure that all employees participate regularly in those Web-based Compliance trainings (e-Learn- ing courses) 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 mail- ings of materials or have their own com- pany-specific processes. To complement such online courses, the Compliance Office regularly carries out trainings requir- ing the participants’ physical presence. Compliance trainings are also an integral part of leadership seminars, management courses and other internal continuing edu- cation and training events at Lufthansa. 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 compliance issues and the current state of the program’s implementation within the Group. Company bodies concerned receive in- depth insight into the regulations of the German Securities Trading Act (WpHG). Integrity Compliance With the module Integrity Compliance, Lufthansa documents its fundamental approach of law-abiding conduct in busi- ness relationships. The obligation to adhere to non-corrupt and ethically correct con- duct flow naturally from current law, the internal compliance guidelines and Lufthansa’s memberships in relevant nation- al and international organizations. Exam- ples of the latter include Lufthansa’s com- mitment to the principles of the UN Global Compact and its membership in Transpar- ency International. The Integrity Compli- ance Guideline provides support in han- dling invitations, gifts and other attentions. Embargo Compliance The module Embargo Compliance serves to ensure that the Lufthansa Group, as a globally active corporation, adheres to country- and person-specific sanctions regulations in the area of foreign trade. The Embargo Compliance guideline provides the employees concerned with a binding framework of conduct. lines. These are binding internal regulations that give employees a precise framework for action which guarantees a standardized and law-abiding external conduct for Lufthansa. The Company is not willing to tolerate possible violations of law on the part of its employees. Culpable breaches of law lead to consequences under labor law and may also entail personal liability. The Lufthansa Compliance Program currently comprises four building blocks: Competition, Capital Market, Integrity and Embargo. Competition Compliance The module Competition Compliance intro- duces employees to the relevant regulations of competition and cartel legislation, so as to minimize or exclude risks for Lufthansa in this area. All employees handling issues relevant to competition or cartels are trained in the fundamental regulations of German and European antitrust legislation. 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 publicity. Accompanied by specialized training, this module assures that all employees and The Lufthansa Compliance Program Program consisting of four modules The Group Compliance Office is responsible for implementation, development and communication. Competition Capital Market Integrity Embargo Sustainability Report Balance // Issue 2015 // Lufthansa Group // 27

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