Deutsche Lufthansa

The Supervisory Board performed the tasks incumbent upon it by law, the Articles of Association and the Rules of Procedure in 2024. It advised the Executive Board on the management of the Company and supervised its activities. The Supervisory Board was directly involved in all decisions of fundamental importance for the Company.

The Supervisory Board discussed regularly with the Executive Board on the Group's strategy, planning, business development, risk position and compliance. The Chairman of the Supervisory Board and the Chairman of the Executive Board maintained regular contact regarding the current development of the business situation and key business transactions. The Chairman of the Supervisory Board was directly involved in key Executive Board decisions.

Executive Board Restructuring The Executive Board of Deutsche Lufthansa AG underwent significant restructuring in the 2024 financial year. The Executive Board was reduced from six to five members and responsibilities were redistributed.

The Executive Board of Deutsche Lufthansa AG had the following members at the end of the 2024 financial year:

• Carsten Spohr, Chairman of the Executive Board
• Michael Niggemann, responsible for Human Resources & Legal, Labour Director
• Till Streichert, responsible for Finance
• Grazia Vittadini, responsible for MRO and IT
• Dieter Vranckx, responsible for Global Markets & Commercial Management Hubs

Committee Structure In the 2024 financial year, the Supervisory Board established five committees. Reports were provided on each of these committees' activities at the start of the following Supervisory Board meeting.

Supervisory Board Committees as of 31 Dec 2024:

Committee Activities:

The Steering Committee met four times in 2024. As in previous financial years, the Steering Committee prepared the Supervisory Board meetings and considered the course of business in detail. The Steering Committee also considered all of the issues relating to the remuneration received by the Executive Board. Moreover, the Steering Committee made recommendations to the Supervisory Board on all personnel and remuneration decisions concerning the Executive Board.

The ESG Committee advises the Supervisory Board, its committees and the Executive Board on issues relating to sustainable corporate governance and the Company's business activities in the ESG areas. It met twice in 2024. Its key areas of focus were the carbon emissions targets specified in the Lufthansa Group's ESG strategy as well as the key reduction and offsetting tools available in order to achieve these targets.

The Audit Committee met five times in 2024, always in the presence of the auditors. As an independent financial expert in line with the requirements of the German Stock Corporation Act and the German Corporate Governance Code, the Chair of the Audit Committee has particular knowledge and experience in the field of accounting, including international control procedures, and in relation to sustainability reporting.

The Supervisory Board was involved in all decisions of fundamental importance for the Company and discussed regularly with the Executive Board on the Group's strategy, planning, business development, risk position and compliance.

Training and Information Events The members of the Supervisory Board – in particular, the members of the ESG and Audit Committees – attended several training events offered by the Company over the course of the 2024 financial year. The topics covered included, in particular, training on the European Corporate Sustainability Reporting Directive (CSRD Directive) and the Lufthansa Group's network and partner management. The Supervisory Board moreover received training in the fields of IT security, international aviation policy and the Lufthansa Group's HR planning. In addition, it visited Eurocontrol in Brussels.

The Supervisory Board was also offered the opportunity to attend information events relating to current issues such as the level of progress made in the Company's acquisition of ITA Airways and its earnings performance in the second quarter of 2024.

Committee Focus Areas: The ESG Committee's key areas of focus were the carbon emissions targets specified in the Lufthansa Group's ESG strategy as well as the key reduction and offsetting tools available in order to achieve these targets.

The Audit Committee discussed the annual financial statements for 2023 and the interim reports for 2024 with the CFO prior to their publication. This committee also dealt with the supervision of accounting processes and the effectiveness of the internal control, risk management and internal auditing systems. Furthermore, the members received regular reports on the compliance management system and capital market communications.

They discussed in detail the 2025 budget, the Group operational planning and the medium-term financial planning for the period from 2026 to 2028. They also regularly discussed the progress made in complying with the requirements of the CSRD Directive for the preparation of a sustainability report, including with the auditor.

Integration of Sustainability in Remuneration Given the central importance of sustainability, this topic is represented at the Executive Board level. Moreover, implementation of the Group's sustainability strategy is accounted for in the remuneration of the Executive Board members and the management levels.

The Lufthansa Group incorporates specific carbon emissions into its management system to lower the associated costs by reducing environmental impacts. This facilitates sustainable value creation, positively affects financing conditions and is also factored into management remuneration.

Performance-Based Remuneration Elements Free cash flow also plays a major role for the variable remuneration of many employees, particularly of managers, and in the performance dialogues with the business entities. With this, the organisation is continuously made aware of its influence on company value and incentives are established to increase the level of free cash flows.

Internal Control and Risk Management Systems The Audit Committee dealt with the supervision of accounting processes and the effectiveness of the internal control, risk management and internal auditing systems. Furthermore, the members received regular reports on the compliance management system and capital market communications.

The auditors confirmed that the system for the early identification of risks established by the Executive Board is suitable for identifying developments which might jeopardise the Company's continued existence at an early stage.

Sustainability Reporting Controls The Audit Committee regularly discussed the progress made in complying with the requirements of the CSRD Directive for the preparation of a sustainability report, including with the auditor. Even though the German parliament did not pass the bill for the implementation of the CSRD Directive by the end of 2024, the Lufthansa Group nonetheless voluntarily opted to prepare a combined non-financial declaration in compliance with the CSRD Directive, and to have EY conduct a limited assurance engagement for this.

Structured Risk Management The Group's financial stability is ensured through integrated risk management. Hedging fuel, exchange rate and interest rate risks minimises the short-term financial risks for the Lufthansa Group. The hedges smooth price fluctuations by means of rule-based processes. Changes in fuel costs can therefore be taken into account in pricing at an early stage.

Business Model and Value Chain

The Lufthansa Group is an aviation group with operations worldwide. It plays a leading role in its European home market. The Lufthansa Group consists of the business segments Passenger Airlines, Logistics, MRO and Additional Businesses.

Core Business - Airlines At the core of the Lufthansa Group are its airlines with their home markets of Germany, Austria, Switzerland, Belgium and Italy and their extensive European and intercontinental route networks. Through two production models – network airlines and point-to-point airlines – they serve the relevant customer and market segments with independent brands and differentiated service promises, connecting Europe with the world.

Passenger Airlines Business Segment The Passenger Airlines business segment includes:

• Network airlines: Lufthansa Airlines, SWISS, Austrian Airlines and Brussels Airlines. As part of a multi-hub strategy, they offer their passengers a broad range of flights from their hubs in Frankfurt, Munich, Zurich, Vienna and Brussels.
• Regional airlines: Lufthansa CityLine, Lufthansa City Airlines and Air Dolomiti as well as Discover Airlines (holiday airline). Edelweiss has a close relationship with SWISS.
• Point-to-point airline: Eurowings provides a comprehensive range of point-to-point connections for short- and medium-haul destinations, particularly from German-speaking countries.

Multi-Hub Strategy and Route Network As part of the multi-hub strategy, Lufthansa Airlines, SWISS, Austrian Airlines and Brussels Airlines offer their passengers a broad range of flights from these airlines' hubs in Frankfurt, Munich, Zurich, Vienna and Brussels. The regional Group airlines provide short-haul feeder services for the network airlines. The network airlines are supplemented on long-haul routes by the route networks of the alliance and joint venture partners, which offer extensive transfer connections.

Fleet Strategy At the end of 2024, the Lufthansa Group fleet comprised 735 aircraft with an average age of 14.0 years. The Group has 242 aircraft on order with delivery periods from 2025 to 2032, plus options for 182 additional aircraft. The ongoing fleet modernisation focuses on:

• Retirement of larger four-engine aircraft that are less fuel-efficient
• Replacement with modern, more efficient aircraft types such as the Boeing 787 and A350
• Up to 30% lower fuel consumption and carbon emissions compared with predecessor models
• Reduction of aircraft model complexity in the long-haul fleet from 13 to 10 types

Additional Business Segments

• Logistics: Lufthansa Cargo provides airfreight services
• MRO: Lufthansa Technik offers maintenance, repair and overhaul services globally
• Additional Businesses: Include Lufthansa Aviation Training and Lufthansa Systems. AirPlus was sold in July 2024.

Value Creation Strategy The passenger airline business is supplemented by other business segments which each have synergies with the airlines. The long-term aim is to focus the portfolio more sharply on the airlines. All Lufthansa Group companies are continuously reviewed with regard to the value they contribute within the Group.

Geographic Presence and Markets The Lufthansa Group has home markets in Germany, Austria, Switzerland, Belgium and Italy. At year-end 2024, the Group had 101,709 employees worldwide, with 65% in Germany and 35% outside Germany. The Group serves destinations across Europe and internationally through its multi-hub strategy.

Stakeholder Engagement

Employees and Workforce The Company-wide employee survey "involve me!" helps to identify strategic areas of action in a targeted manner and to integrate these within the Group's HR strategy. The Lufthansa Group pursues a comprehensive approach which ensures equal opportunity, promotion of diversity, professional training and a work-life balance.

Collective Bargaining and Social Partners In the 2024 financial year, the Lufthansa Group reached a large number of new pay settlements with its collective bargaining partners. Within the scope of its social and collective bargaining policies, the Lufthansa Group aims to define good working conditions and fair salary arrangements which strike a balance between the interests of the companies and employees in every part of the Group.

Key Collective Agreements Signed in 2024:

• Ground staff (Germany): AGVL and ver.di signed a new wage agreement for around 20,000 ground staff with average wage increases of up to 12.5% in two phases
• Cabin crew (Germany): AGVL and UFO signed a wage agreement for approximately 19,000 cabin crew with gradual salary increases of 16.5% total over three years
• Austrian Airlines: Signed new collective agreements for around 2,400 flight attendants and 1,000 pilots with gradual salary increases of around 19.4% in three phases
• Brussels Airlines: New wage agreements for pilots and cabin crew running until end of 2026
• Eurowings: New collective agreements for pilots and cabin crew with substantial adjustments

Customers and Service Development Customers are at the heart of the Group strategy. The Lufthansa Group aims to offer travel products with the highest quality standards as well as consistent solutions along the entire travel chain. Customer communication activities are adjusted in line with the Lufthansa Group's various customer segments and tailored to their individual requirements.

Customer Loyalty and Engagement:

• Net Promoter Score (NPS) as indicator of customer satisfaction
• Expansion of Lufthansa Group Travel ID for personalized services
• New digital customer services and automated processes
• Customer portal for self-service options and issue resolution

Industry and Partners Cooperation with partner airlines is becoming more important in order to strengthen market presence in key traffic regions and offer customers attractive connecting flights. The Lufthansa Group's successful joint ventures are being developed and partnerships expanded in key markets.

Sustainability Stakeholders The Lufthansa Group is working with policymakers and partners in industry, technology and research to promote the increased use of sustainable aviation fuel (SAF). The Group also actively supports its assessment by relevant international ESG ratings, such as MSCI, Sustainalytics, CDP and ecovadis, to ensure transparency regarding its activities and progress.

Community Engagement In terms of social responsibility, the Company supports disadvantaged people worldwide with financial and personnel support for educational establishments and training provided by help alliance, the Group's own aid organisation.

Material Impacts, Risks and Opportunities

Climate Change and Environmental Impacts

The Lufthansa Group faces significant material impacts related to climate change and environmental sustainability:

Climate Targets and Strategy:

• Target to cut net carbon emissions in half by 2030 compared with 2019
• Support for making aviation carbon neutral by 2050
• Target to cut carbon emissions per revenue tonne-kilometre by 30.6% by 2030 compared with 2019 (SBTi validated)
• Specific carbon emissions per passenger-kilometre were 87.5 grammes in 2024 (1% lower than previous year)

Financial Impact of Climate Regulations:

• EU ETS certificate costs increased by EUR 134m in 2024 due to discontinued free allocations
• Expected significant cost increases from sustainability-related expenses including SAF quota and loss of free emissions certificates
• European blending quotas for sustainable aviation fuel (ReFuelEU Aviation) creating competitive disadvantages

Operational and Strategic Responses:

• Investing continuously in fuel-efficient aircraft alongside measures to boost operational efficiency
• Fleet modernisation with up to 30% lower fuel consumption and carbon emissions
• Systematic expansion of intermodal traffic in all home markets
• Working with industry partners to promote increased use of sustainable aviation fuel (SAF)
• Introduction of Green Fares including carbon offsets

Market and Competitive Risks

Capacity and Delivery Challenges:

• Ongoing delays in delivery of new aircraft causing capacity bottlenecks
• Average of around 30 aircraft unavailable due to PW1100G engine inspections
• Use of wet leases to compensate for capacity constraints

Cost Pressures:

• Significant cost increases expected due to sustainability-related expenses
• Cost inflation in materials, fees and charges, and staff costs
• Need for efficiency improvement programmes across business segments

Yield Pressure:

• Market-wide capacity growth intensifying price pressure
• Yields declining due to increased competition
• Careful balance needed between market share, yields and capacity allocation

Operational Risks and Opportunities

Strike Impact:

• Strikes in first quarter 2024 reduced earnings by around EUR 450m
• Impact from both employee groups and system partners

Geopolitical Impacts:

• Russian airspace closure requiring longer flight routes
• Middle East conflict causing flight cancellations (EUR 100m earnings impact)
• Temporary suspension of flights to various Middle Eastern destinations

Business Transformation Opportunities:

Turnaround Programmes:

• Lufthansa Airlines turnaround programme targeting EUR 2.5bn earnings impact by 2028
• Group-wide efficiency and earnings improvement programmes
• Focus on increasing unit revenues and reducing unit costs

Strategic Positioning:

• Leading European airline group position
• Multi-hub strategy providing competitive advantage
• Premium positioning in relevant market segments

Technology and Innovation Opportunities:

• Fleet modernisation driving improved efficiency
• Digital transformation enhancing customer experience
• Development of sustainable aviation solutions

Financial Strategy Integration:

The material impacts are integrated into the Company's value-based management system:

• Adjusted ROCE target of at least equal to WACC
• Specific carbon emissions incorporated into management remuneration
• Investment decisions evaluated against value creation criteria
• Three-pillar financial strategy: sustainable value creation, strong free cash flows, financial stability

Description of the process to identify and assess material impacts, risks and opportunities

Overview

The Lufthansa Group defined the material impacts, risks and opportunities as part of a double materiality analysis. In order to identify, evaluate and monitor their material impacts, risks and opportunities (IROs for short), the Lufthansa Group conducted a four-stage process during the reporting year. This process is planned to be further monitored in future reporting years as part of the materiality analysis and adjusted if necessary.

Four-stage methodology

1. Potential impacts of the core business have been reviewed

The materiality process started with an in-depth review of the core business activities of the Lufthansa Group. These were analysed with regard to potential environmental and social impacts, with a particular focus on the entire value chain, including direct and indirect business relationships. Geographically, the focus was on regions in which the Lufthansa Group is most active and could have potential impacts. In Europe, where the headquarters and main hubs for the Group are located, this included the management of impacts relating to the passenger airlines network. Activities in North, Central and South America, in the Asia/Pacific region, the Middle East and Africa were also analysed in order to take into account region-specific IROs.

In terms of the identification of IROs, the focus was on the Lufthansa Group value chain, including direct and indirect business relationships. This means that the analysis not only included risks that could arise from relationships with primary suppliers, for example, but also those that could arise from other upstream stages of the value chain, as far back as raw material extraction.

As part of this process, the material impacts were first identified. The relevant risks and opportunities were then attributed to these impacts. This meant that IRO pairs were created within the process, which enabled a comprehensive analysis of the topics. Individual risks and opportunities that were not directly linked with any identified impacts were labelled in order to highlight their separate significance in the overall context.

2. IRO inventory along the value chain is created

An initial IRO inventory was made for relevant sustainability aspects as per the CSRD and/or the corresponding ESRS directives. To do this, a description of the value chain was created for each of the core business activities. Using the value chains and taking into account the stakeholders affected, the actual and potential impacts, risks and opportunities were identified and recorded in the IRO inventory. This was based on the existing risk inventory for the Lufthansa Group, reports for the Lufthansa Group, industry input, public information, reports and databases – for example, ENCORE – as well as the results of the wide-ranging stakeholder survey from 2023 and the expertise of representatives of the subsidiaries for select IROs.

3. IROs are then evaluated

Assessment of risks and opportunities ("outside in" principle)

The identification and subsequent assessment of the risks and opportunities was done using the "outside in" principle. As such, external factors were considered that have an impact on the Company and opportunities and risks for the Lufthansa Group were derived from these factors. These risks and opportunities were assessed using a method agreed with Group Risk Management.

Time horizons:

• Short-term: up to one year
• Medium-term: between one and four years
• Long-term: four years or longer

The assessments were made on the basis of the time horizon within which the risk or opportunity was deemed most likely to be material.

Magnitude assessment:

The magnitude of each risk and opportunity was first assessed. The magnitude refers to potential impacts on the development, financial position, operating result, cash flow, access to financing or cost of capital of the Company and was assessed on a scale of 1 (insignificant) to 5 (critical). This assessment was carried out from a gross perspective, without taking into account any mitigating measures. It took into account factors such as potential financial losses, the degree of long-term damage to the Lufthansa Group, the type of financial impacts on the Group, the extent of operational breakdowns and the impacts on the reputation, business model, liquidity, assets or income of the Lufthansa Group, as well as the potential financial extent of the damage. For the opportunities, the extent was measured using the potential improvement of the Lufthansa Group's financial position, the impacts on business operations and the extent of operational improvements.

Likelihood assessment:

The likelihood of the risk or opportunity was then categorised using the expected frequency of occurrence:

• Irrelevant: between once in 50 years and once in ten years
• Low: between once in ten years and once in five years
• Moderate: between once in five years and once in three years
• High: between once in three years and once in two years
• Extremely high: at least once in two years

Any established processes, such as existing effective ICS processes, were generally included in the assessment, which contributed to the likelihood being downgraded.

If the magnitude and/or likelihood exceeded the defined thresholds, the relevant risk or opportunity was considered material. In order to categorise the magnitude and likelihood, a brief explanation was documented for each analysis.

Assessment of impacts ("inside out" principle)

The identification and subsequent assessment of the impacts was done using the "inside out" principle. The analysis addressed how the Lufthansa Group's business activities along the value chain affect people and nature. The assessment process closely reflects the methods used to measure risks and opportunities in order to create a coherent approach across all relevant areas. The defined short-term, medium-term and long-term time horizons are also applied. Here, too, the time horizon to be considered is based on the period from which the impact is the most likely to be considered material, with the time period of the highest severity being selected if several time horizons apply.

Severity assessment:

The severity of the impact was then measured. For positive impacts, the parameters of scale and scope are included, while for negative impacts, scale, scope and irremediability had to be assessed. These measurements were made on a scale of 1 (least severe) to 4 (most severe) from a gross perspective – any mitigating measures were therefore not taken into account in the measurement. For potential impacts, the likelihood was also assessed on a scale of 1 (irrelevant) to 5 (extreme). Any established assessment processes were also generally used here.

An explanation was also recorded here in order to explain the assessments, whereby the expected time horizon was specified in particular for long-term impacts. The materiality of an impact was determined by the classification under severity dimensions, while potential impacts were measured using a combination of severity and likelihood in order to determine thresholds for materiality.

Materiality thresholds:

The Lufthansa Group applied a consistent approach to thresholds for all impacts, risks and opportunities. These are the same as the thresholds used for external reporting by the Lufthansa Group ERM system. When determining the materiality of potentially negative impacts in relation to human rights, the severity took precedence over the likelihood.

4. External preliminary evaluation results validated by internal experts

After the methods were established, the Lufthansa Group selected the approach of industry experts and subject matter experts pre-evaluating IROs by including desktop research and online publications. The results of the preliminary evaluation were then validated by internal subject matter experts at the Lufthansa Group. After the validation, internal representatives from the key stakeholder groups carried out a validation of the results from the perspective of the stakeholders. This involved validating the results with the Investor Relations and Customer Experience departments. In a second validation, the results were analysed from various management perspectives and presented to the management together with an overview of the evaluation process. The management reported back on the materiality of specific sub-topics, which were then sent back to the internal experts and stakeholder representatives in order to ensure agreement with the expertise of the internal experts and to make any necessary amendments. The final results of this extensive validation process were then shared with the employee representatives, the Executive Board and the Supervisory Board.

The results were sent to the Executive Board in August 2024 and presented to the Supervisory Board within the ESG Committee in September 2024. The results were also discussed, recorded and documented in an internal steering committee of the CSRD project in mid-July 2024 in order to create a comprehensive decision-making basis for the management.

Integration with risk management

The process of identifying and measuring material impacts, risks and opportunities was newly developed within the Lufthansa Group in order to comply with the requirements of the CSRD and ESRS. It builds on the existing materiality analysis.

Planned integration:

The CSRD-related risks for the Lufthansa Group were derived as part of the double materiality analysis described. The underlying risk methods were adapted to the Group risk management so that CSRD-relevant risks could be integrated into the Company's regular risk management process. In the coming years, CSRD risks will become an integral component and the standard methods and processes with CSRD-relevant features will be applied, where necessary.

As part of the double materiality analysis in 2024, ESG risks were identified and evaluated by the Corporate Responsibility department in accordance with ESRS requirements for the first time. The underlying risk methodology was adapted from the Group-wide risk management methodology, including the risk scales and risk types, for example. There were material differences to the existing Group risk management in terms of the dedicated ESRS categories, extended time horizons (short, medium and long term), and a consideration of risk before any remedial action.

An integration process was defined for the years 2024 to 2026 with the aim of integrating further ESG-risks into Group risk management as a whole and into the regular risk management process. The standard methodology and processes are adapted where necessary with CSRD-relevant specifics.

The process for identifying, measuring and managing CSRD risks is tailored to the methods used in Group risk management. The risks are recorded and measured by probability and impacts (qualitative and quantitative). In 2024, CSRD risks were assessed qualitatively from a gross perspective and transferred into the central ERM platform.

In future, CSRD risks are to be integrated into the regular ERM process and to be considered part of the overall risk situation.

Identification of opportunities

The identification, measurement and management of opportunities have not yet been seamlessly integrated into the overall management system.

Attribution to ESRS topics

All material IROs have always been attributed to the relevant sub-topic in the ESRS framework. As soon as just one individual IRO was evaluated as material, the relevant sub-topic was defined as material.

Frequency of review

The ESRS contain specific requirements with regard to the intervals at which a materiality analysis must be conducted. For material changes to the Lufthansa Group business model, such as establishing a new business segment or in the event of major acquisitions, the topics in the materiality analysis will need to be re-evaluated. Furthermore, the materiality analysis must be reviewed annually for changes and to ensure that it is up to date.

Topic-specific methodologies

E1 - Climate change

Physical scenario analysis:

Two climate scenarios from the Intergovernmental Panel on Climate Change (IPCC) were selected:

• SSP1-2.6 (sustainable development scenario, low emissions)
• SSP5-8.5 (fossil-fuelled development scenario, high emissions)

For flight operations, important drivers with regional and/or local impact such as heatwaves, storms, changes in the jet stream, an increase in turbulence and severe thunderstorms were taken into account.

The value chain was mapped and divided into the business segments Passenger Airlines, Lufthansa Cargo and Lufthansa Technik. In line with the EU Taxonomy, a list of 28 climate risks was evaluated, of which 15 were selected for the scenario analysis. In total, 25 sites were identified for the scenario analysis: 20 local, physical sites, including airports, hubs, supplier and maintenance facilities and five regions that covered important flight routes. In the scenario analysis, data from a climate scenario with low emissions (SSP1-2.6) and from a climate scenario with high emissions (SSP5-8.5) were used to assess the potential changes in physical risks over time, namely for the time horizons 2024, 2030 for a medium-term and 2050 for a long-term view. In addition, exposure assessments for each facility type were assigned at the site level to reflect the exposure of the individual facilities. Finally, the exposure assessments and the normalised climate data were combined to calculate the risk values for each individual hazard and each site. The risk values were categorised on a multi-level scale, which enabled a comparison between different hazards and facility locations to determine relative risk levels.

Transition scenario analysis:

The "Stated Policies Scenario" and the "Net Zero Scenario 1.5°C" of the International Energy Agency (IEA) were selected. These scenarios are suitable for identifying and analysing all relevant transition risks and opportunities, particularly in connection with climate policy and technological developments in the energy sector. Important drivers for the aviation industry were taken into account in the transition scenario analysis, such as the development of the CO2 price, passenger-kilometres flown, fuel prices and other energy and CO2 intensity indicators.

The value chain was mapped with a distinction made between the business areas Lufthansa Airlines, Lufthansa Cargo and Lufthansa Technik. A list of potential transition risks and opportunities was created and evaluated for relevance. In total, nine transition risks and opportunities were shortlisted for the scenario analysis. Each risk and each opportunity were evaluated for a separate business area and the risks were weighted accordingly. For the evaluation of transition risks, the year 2030 was defined as the short-term, 2040 as the medium-term and 2050 as the long-term time horizon.

E2 - Pollution

No other sites or assets were analysed with regard to pollution because the Lufthansa Group only operates a very limited number of production processes at its sites. For this reason, a site-based analysis was not a suitable method for the Lufthansa Group to identify material impacts, opportunities and risks.

The impacts of noise pollution by aircraft were part of the stakeholder surveys carried out in 2018 and 2023, where stakeholders, including representatives from affected communities, were able to submit a quantitative assessment on the sustainability-related topic of noise pollution. Stakeholders were also able to submit qualitative feedback in the form of comments. In addition, the analysis conducted by the Lufthansa Group's internal experts also took into account insights from local dialogue forums involving residents near airports.

E3 - Water and marine resources

No other sites or assets were analysed with regard to water and marine resources because the Lufthansa Group only operates a very limited number of production processes at its sites. In this context, a site-based analysis was not a suitable method for the Lufthansa Group to identify material impacts, opportunities and risks.

The potential impacts of the Lufthansa Group on water resources were part of the stakeholder surveys carried out in 2018 and 2023, in which participants were able to submit a quantitative assessment on the sustainability-related topic of water. Stakeholders were also able to submit qualitative feedback in the form of comments.

E4 - Biodiversity and ecosystems

No other sites or assets were analysed with regard to biodiversity because the Lufthansa Group only operates a very limited number of production processes at its sites. For this reason, a site-based analysis was not a suitable method for the Lufthansa Group to identify material impacts, opportunities and risks.

Dependency on ecosystem outputs was addressed as part of the double materiality analysis described under IRO-1 and specific impacts, risks and opportunities were formulated. In doing so, the upstream and downstream value chain of the Lufthansa Group was taken into account. However, the defined impacts, risks and opportunities were not identified as being material. The materiality analysis also considered potential opportunities, as well as physical and transition risks, which were also not deemed material. A more comprehensive analysis was therefore not conducted. Systemic risks were not considered within the double materiality analysis.

No consultations were conducted with affected communities regarding shared biological resources or ecosystems because no material negative impacts were determined in this regard.

No actual or potential site-specific impacts, risks and opportunities were identified as part of the double materiality analysis. For this reason, a more detailed evaluation was not conducted to establish whether the Lufthansa Group sites are located near areas that are essential to maintaining biodiversity.

The double materiality analysis did not reveal any actual or potential material impacts that would require the implementation of additional remedial measures.

E5 - Resource use and circular economy

No other sites or equipment were analysed with regard to resource use and the circular economy because the Lufthansa Group only operates a very limited number of production processes at its sites. For this reason, a site-based analysis was not a suitable method for the Lufthansa Group to identify material impacts, opportunities and risks.

The potential impacts of the Lufthansa Group on resource use and the circular economy were part of the stakeholder surveys carried out in 2018 and 2023 where participants were able to submit a quantitative assessment on the sustainability-related topic of resource use and the circular economy. Stakeholders were also able to submit qualitative feedback in the form of comments.

Transition plan for climate change mitigation

Scope of the plan

The Lufthansa Group's Climate Transition Plan covers:

• Entities: All business segments including Passenger Airlines, Lufthansa Cargo and Lufthansa Technik
• Geographies: Global operations, with specific targets for ground operations in Germany, Austria and Switzerland
• Value chain segments: Activities that are part of the Lufthansa Group's own operations (Scope 1) as well as upstream and downstream activities in the value chain (Scope 3, Category 3)

Net zero / carbon neutral targets

• 2050: Carbon neutrality target
• 2030: Halve net CO₂ emissions compared with 2019 (through reduction and offsetting measures)
• Ground operations (DACH region): Carbon-neutral by 2030, sourcing electricity exclusively from renewable energies

Science-based reduction milestones

SBTi validated targets (2022):

• Baseline year: 2019
• Target: Reduce carbon intensity (CO₂ emissions in grammes per revenue tonne-kilometre) by 30.6% from 2019 to 2030
• Scope coverage: Scope 1 and Scope 3, Category 3 for aircraft operations; market-based Scope 2 for ground operations

Interim milestone for LTI 2024:

• 11 percentage point reduction in carbon intensity by end of performance period on 31 December 2027

The Lufthansa Group used 2019 as its base year because that was the last operating year unaffected by the coronavirus crisis in terms of emissions when the targets were set.

Alignment with 1.5°C / SBTi validation status

• SBTi validation: Validated in 2022, making the Lufthansa Group the first airline group in Europe and the second worldwide with a scientifically verified CO₂ reduction target in line with the goals of the Paris Climate Agreement of 2015
• Paris alignment: The SBTi target is in line with limiting global warming to well below two degrees as set out in the Paris Agreement. The net-zero target for 2050 and net-emissions target of –50% for 2030 help limit global warming to only 1.5°C as set out by the IPCC
• EU Paris-aligned benchmarks: The Lufthansa Group is not exempt from the EU's Paris aligned benchmarks

Key decarbonization levers and contribution to 2030 SBTi target

The Lufthansa Group has identified a four-pillar climate change mitigation strategy:

1. Technical advances
2. Better infrastructure
3. Operational measures
4. Economic instruments

Quantified contributions of individual decarbonisation levers to achieving the SBTi target in 2030:

• Fleet renewal: Reduces GHG emissions per revenue tonne-kilometre (RTK) by a projected 15% based on current framework conditions such as the supply reliability of aircraft manufacturers
• Operational efficiency measures: Reduce GHG emissions per RTK by a projected 3.8% based on current framework conditions such as the networked utilisation of European airspace
• Sustainable Aviation Fuels (SAF): Additionally reduce GHG emissions per RTK by 3.4%

Specific measures:

• Fleet modernisation: The Lufthansa Group fleet was expanded by 18 new aircraft in 2024, including Airbus A320neos, A321neos, A350-900s and Boeing 787-9s, which are powered by modern engines. The A320neo is one of the world's newest and most environmentally friendly aircraft
• AeroSHARK retrofit: Applies an innovative surface technology that improves aircraft fuel efficiency
• Intermodal transport: Expanding the range of intermodal transport by working with other transport companies to include more train and bus connections as alternatives to short-haul flights
• Alternative propulsion technologies: Monitoring developments in electric, hybrid-electric, and hydrogen-powered solutions for short-haul flights through Aircraft Evaluation and Market Intelligence teams. Lufthansa Technik initiated the Hydrogen Aviation Lab in 2021, a project funded by the City of Hamburg. The fully functional stationary field laboratory has been in operation since the end of 2024
• Ground operations: Strategic planning for vehicle fleet electrification, overseen by the Infrastructure department
• Atmospheric research: Since 1994, actively supporting various national and international atmospheric and climate research projects, including IAGOS (In-service Aircraft for a Global Observing System)

CapEx / investment commitments

• 2024 aircraft investments: Inpayments, own payments and final payments for aircraft, aircraft components, and aircraft and engine overhauls were up by 4% to EUR 3,923m (previous year: EUR 3,789m). This represents 86% of total capital expenditures
• EU Taxonomy reporting: The Lufthansa Group reports EUR 3,912m in taxonomy-eligible capital expenditure, representing 86% of total capital expenditure for Activity 6.19 Passenger and Freight Air Transport
• Taxonomy alignment: Of the Lufthansa Group's total capital expenditure, 0% is taxonomy-aligned within Activity 6.19 due to requirements exceeding European regulation referenced in Annex C. Assuming requirements are equivalent, the Lufthansa Group considers that 62% of its capital expenditure is taxonomy-aligned

Governance and integration

Executive Board oversight:

• The Transition Plan was developed alongside the corporate strategy and was presented and approved in a special meeting of the Executive Board
• Continuous exchange between the Corporate Responsibility team and the Fleet Renewal department to coordinate efforts
• A designated contact from flight operations monitors progress and effectiveness of fuel efficiency measures, directly informing the Corporate Responsibility department

Supervisory Board:

• Set the reduction of specific CO₂ emissions as a core focus for strategic goals and sustainability targets within long-term variable remuneration for the 2024 financial year (LTI 2024)
• Environmental objective has a weighting of 20% in the assessment of target achievement for LTI 2024
• The indicator is grammes of CO₂ per revenue tonne-kilometre transported, in line with the SBTi targets

Financial planning integration:

• The Climate Transition Plan is closely linked to financial planning
• Fleet renewal plays a critical role and requires substantial capital expenditure every year
• The level of fuel efficiency gains and GHG emission reductions depends on investment levels and availability of new aircraft

Climate resilience analysis

The Lufthansa Group initiated a climate resilience analysis in collaboration with an external consulting firm during financial year 2024, aiming to analyse the resilience of the strategy and business model to climate change.

Scenario analysis:

Physical risks - Two IPCC climate scenarios:

• SSP1-2.6 (sustainable development scenario, low emissions)
• SSP5-8.5 (fossil-fuelled development scenario, high emissions)
• Time horizons: 2024, 2030 (medium-term), 2050 (long-term)
• 25 sites identified: 20 local physical sites (airports, hubs, supplier and maintenance facilities) and 5 regions covering important flight routes

Transition risks and opportunities - Two IEA scenarios:

• "Stated Policies Scenario"
• "Net Zero Scenario 1.5°C"
• Time horizons: 2030 (short-term), 2040 (medium-term), 2050 (long-term)
• Nine transition risks and opportunities shortlisted for scenario analysis

Key climate-related risks identified:

Transition risks:

• Higher operating costs due to increasing CO₂ price within European and international CO₂ trading systems (EU ETS and CORSIA)
• Higher operating costs due to rising kerosene prices as a result of upcoming legislation on the use of fuels for aviation
• Lack of availability and high prices for SAF, accompanied by mandatory, continuously rising blending quota from 2025 onwards for flights taking off from European airports
• Price fluctuations for conventional fuels as a result of stricter regulations and market trends to promote a low-carbon economy

Physical risks:

• Disruptions in operations and consequently higher operating costs as a result of heatwaves

Key climate-related opportunities identified:

• Increase and acceleration of the development of new sustainable aircraft technologies

Resilience strategies:

For heatwaves, central strategies developed include:

• Improved climate control for infrastructure and buildings
• Prioritising maintenance of cooling systems
• Training employees to prepare them for potential risks and promote safety

For transition risks, key mitigation measures include:

• Continuous renewal of the fleet
• Optimised use of SAF to benefit from incentives under emissions trading systems and meet self-imposed sustainability targets
• Research and development of innovative, more climate-friendly technologies
• Strengthening interaction with industry associations to develop effective policy proposals

Use of carbon credits / removals

Carbon offset contributions:

• Beyond the SBTi reduction target, voluntary carbon offsets contribute to the self-imposed goal of halving net carbon emissions by 2030 compared with 2019
• Carbon offset contributions flow into a portfolio of climate change mitigation projects in various countries including Germany, Austria and Switzerland
• Supported by organisations myclimate, Climate Austria, and the Green Fare offsetting tariff offered by Lufthansa Group airlines
• Participation in CORSIA as a mandatory offsetting scheme

Carbon certificates retired in 2024:

Future commitments:

• Carbon certificates to be retired in future based on volume sold by Lufthansa Group in 2024: 657,235 t CO₂e
• 3% of retired certificates relate to projects carried out in Europe
• The Lufthansa Group has not retired any carbon certificates that fall under Article 6 of the Paris Climate Agreement

High certification standards:

• All current projects in the climate change mitigation portfolio are certified to high standards
• Over 90% certified to Gold Standard

Approach to carbon credits:

• Investments in operational reduction measures are prioritised over carbon credits
• Carbon credits are considered indispensable as a means of carbon offsetting for a sector that is difficult to decarbonise
• Customers purchase and finance carbon credits, meaning no investment funds become permanently tied up that could otherwise be allocated to other reduction measures
• Aviation will be reliant on the use of carbon certificates in the long term

Customer offerings

Green Fares:

• Offered on intra-European routes and, since December 2024, on intercontinental routes
• When choosing this fare, 20% of flight-related carbon emissions are reduced on European routes and 10% on long-haul flights
• The remaining share of carbon emissions is offset through contributions to the Lufthansa Group's climate change mitigation portfolio

Lufthansa Cargo Sustainable Choice:

• Customers can offset airfreight-related carbon emissions by investing in SAF or carbon offsetting projects
• Five different options available for individual airfreight transports, ranging from 100% offsetting to combinations of 20% SAF/80% offsetting up to 80% SAF/20% offsetting
• Corporate customer bulk contracts (bulk agreements) for SAF and carbon offsetting projects

Employee business travel:

• Since 2019, the Lufthansa Group has been voluntarily offsetting carbon emissions from all employees' business flights globally

Non-CO₂ emissions

The Lufthansa Group has not yet defined targets for other climate-relevant non-CO₂ gases. It is currently conducting research to develop a uniform standard for converting these into CO₂ equivalents (CO₂eq) or another appropriate metric. Once established, the Lufthansa Group will define and set targets. To date, neither researchers nor legislators have made a clear determination regarding the parameters to be used or the time period over which the effects are to be considered.

Anticipated financial effects (phase-in)

The Lufthansa Group is making use of the option available under ESRS 1 Paragraph 137 to omit the disclosures required under ESRS E1-9 in the first year of preparation of its consolidated non-financial statement.

Policies related to climate change mitigation and adaptation

Deutsche Lufthansa does not disclose a single named climate policy document under ESRS E1-2. Instead, the company describes its climate approach through a four-pillar climate change mitigation strategy and various commitments and frameworks, but these are presented as strategic approaches rather than formal, named policies.

Four-pillar climate change mitigation strategy

Scope:

• Applies to all airlines in the Lufthansa Group
• Covers flight operations and ground operations (with vehicle fleet electrification under development)

Key content / principles: The strategy addresses four areas for action, originally defined by the International Air Transport Association (IATA) in 2007:

1. Technological progress – Innovation in aircraft and engine technology, alternative fuels
2. Improved infrastructure – Better use of airspace, needs-based airport infrastructure, expansion of intermodality
3. Operational measures – Efficient aircraft sizes, optimum flight routes and speeds
4. Economic instruments – Global market-based system of emissions reduction (CORSIA), voluntary compensation option

Approval and oversight:

• The Transition Plan was developed alongside the corporate strategy and was presented and approved in a special meeting of the Executive Board
• The Executive Board of the Lufthansa Group bears ultimate responsibility for implementing the strategy within the Company
• The Supervisory Board has set the reduction of specific CO₂ emissions as a core focus for strategic goals and sustainability targets within long-term variable remuneration (LTI 2024), with a 20% weighting

Monitoring:

• Annual measurement of GHG emissions compared to the reduction target by comparing the emissions model with actual performance based on fuel consumption and revenue tonne-kilometres (RTK)
• Sale of climate change mitigation projects through CO₂ credits (offsetting)
• Use of SAF tracking
• Annual reporting on per-flight climate impacts (legally mandated from 2025)

Public availability:

• The strategy is communicated to all relevant stakeholders both internally and externally (specific publication location not stated)

Links to international standards:

• Science Based Targets initiative (SBTi) validated targets aligned with Paris Climate Agreement goals
• United Nations Global Compact (member since 2002)
• EMAS (environment in general) and ISO 50001 (energy) standards considered in developing commitments
• Relevant German and EU-wide regulations

Climate change mitigation commitments

While not presented as a standalone policy document, the company has made the following formal commitments:

Targets:

• Halve net CO₂ emissions by 2030 compared with 2019 (through reduction and offsetting)
• Achieve carbon neutrality by 2050
• SBTi-validated target: reduce carbon intensity (CO₂ emissions in grammes per revenue tonne-kilometre) by 30.6% from 2019 to 2030

Ground operations commitment: The company has developed commitments for ground operations including EMAS-certified environmental management system and energy consumption reduction, though monitoring processes were still under development at the end of the reporting year.

Collaboration and research initiatives

The Lufthansa Group participates in various private and government-funded collaboration, research and development initiatives, including:

• Atmospheric research funding since 1994
• Hydrogen Aviation Lab (initiated by Lufthansa Technik in 2021, funded by City of Hamburg)
• Research projects on contrails and climate impacts
• Engagement with industry associations to develop policy proposals

Absence of climate adaptation policy

The company explicitly states: "At present, the Lufthansa Group is focused on limiting the negative impacts of climate change. Whether climate change adaptation measures are necessary will be shown by the evaluation of the climate risk analysis results."

No dedicated climate adaptation policy has been disclosed.

Actions and resources in relation to climate change policies

The Lufthansa Group implements a broad range of measures across a four-pillar climate change mitigation strategy to advance climate change mitigation in the aviation industry:

Four Pillars for Climate Protection

1. Technological progress
2. Improved infrastructure
3. Operational measures
4. Economic instruments

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Pillar 1: Technological Progress

Fleet Renewal

Scope: Own operations

Description: Fleet renewal is the key driver for reducing CO₂ in the short and medium term. Investment in modern, fuel-efficient aircraft and engine technologies represents the most important element in reducing carbon emissions from flight operations.

Actions taken (2024):

• Fleet expanded by 18 new aircraft including Airbus A320neos, A321neos, A350-900s and Boeing 787-9s
• Four aircraft removed from the Group fleet
• Proportion of fleet fitted with latest technology more than doubled to 22% (158 aircraft) since 2019

Resources allocated:

• EUR 3,912m invested in fleet renewal in 2024
• Order backlog comprises around 240 aircraft featuring the latest technology

Time horizon:

• Short to medium term
• Approximately 30 state-of-the-art aircraft expected for delivery in 2025

Expected outcomes:

• Projected 15% reduction in GHG emissions per revenue tonne-kilometre (RTK) based on current framework conditions

Link to targets: This capital expenditure is taxonomy-eligible and reported under Activity 6.19 Passenger and freight air transport within Environmental Objective 1 – Climate change mitigation. Supports SBTi validated target of 30.6% reduction in CO₂ intensity by 2030 from 2019 baseline.

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AeroSHARK Retrofit Technology

Scope: Own operations

Description: Functional surface coating developed by Lufthansa Technik together with BASF. Microscopically small ribs modelled on shark skin ('riblet films') reduce air resistance of large commercial aircraft.

Actions taken (2024):

• 17 Boeing 777s fitted with AeroSHARK in service (12 Boeing 777-300ERs at SWISS, 5 Boeing 777Fs at Lufthansa Cargo)

Expected outcomes:

• Reduction in kerosene consumption by around 0.8%

Link to targets: Contributes to operational efficiency measures for SBTi target achievement.

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Sustainable Aviation Fuels (SAF)

Scope: Own operations and upstream value chain

Description: Expansion of SAF is a key measure for making air travel more climate-friendly. Three-part strategy: continuous procurement on spot market, partnerships, and investments.

Resources allocated:

• Up to USD 250m released by Executive Board for SAF procurement

Time horizon: Ongoing period

Expected outcomes:

• Projected 3.4% reduction in GHG emissions per RTK based on current framework conditions (availability and economic viability)
• Enables compliance with EU Taxonomy technical assessment criteria for Activity 6.19

Link to targets: Supports SBTi validated target and net-zero target for 2050.

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Research and Development Initiatives

Scope: Own operations and value chain partnerships

Description: Involvement in private and government-funded collaboration, research and development initiatives. Working with scientific community on atmospheric research.

Non-financial resources: Partnerships with research institutions, manufacturers (Airbus, Boeing), and technology companies

Time horizon: Long term

Activities: Monitoring developments in alternative propulsion technologies including electric, hybrid-electric, and hydrogen-powered solutions for short-haul flights through Aircraft Evaluation and Market Intelligence teams.

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Pillar 2: Improved Infrastructure

Expansion of Intermodal Transport

Scope: Downstream value chain

Description: Working with other transport companies to include more train and bus connections as alternatives to short-haul flights, encouraging passengers who travel via hubs to use intermodal modes of feeder transportation.

Link to targets: Reduces number of particularly short flights, contributing to overall emissions reduction strategy.

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European Airspace Efficiency Projects

Scope: Own operations and infrastructure partnerships

Description: Participation in SESAR research and demonstration projects (SESAR 3) with various Lufthansa Group airlines and Lufthansa Systems as IT provider.

Actions taken (2024):

• SWISS participated in three projects launched in 2023 relating to optimised flight management and arrival time management in Zurich (Horizon Europe funding programme)

Expected outcomes:

• Implementation of short-term efficiency gains
• Better use of airspace and needs-based airport infrastructure

Link to targets: Operational efficiency measures projected to reduce GHG emissions per RTK by 3.8%.

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Pillar 3: Operational Measures

Description: Efficiency gains through operational measures aligned with the Lufthansa Group's objectives, including:

• Efficient aircraft sizes
• Optimum flight routes and speeds

Expected outcomes: Projected 3.8% reduction in GHG emissions per RTK based on current framework conditions (networked utilisation of European airspace)

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Pillar 4: Economic Instruments

Description:

• Global market-based system of emissions reduction (CORSIA)
• Voluntary compensation option supporting certified climate change mitigation projects

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Cross-cutting: Customer Engagement Products

Scope: Downstream value chain

Actions:

• Green Fares offering
• Sustainable Choice products
• Carbon savings calculations for corporate customers
• Marketing through digital advertisements, sales presentations, webcasts

Link to targets: Enables customer participation in SAF adoption and emissions reduction.

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Ground Operations Decarbonisation

Scope: Own operations (DACH region)

Target: Carbon-neutral ground mobility in Germany, Austria and Switzerland by 2030

Actions: Ground operations electricity sourcing from renewable energies exclusively

Link to targets: Covers market-based Scope 2 emissions; not sector-pathway verified.

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Overall Progress (2024)

Combined reduction in carbon emissions per RTK: 3.8% compared with base year 2019 (SBTi KPI)

Main challenges:

• Delays in delivery of modern aircraft preventing planned fleet renewal
• Geopolitical situations requiring flight detours (Russia/Ukraine conflict, Middle East crisis) increasing fuel consumption

Total capital expenditure (fleet-related): EUR 3,923m in 2024 (up 4% from EUR 3,789m in 2023), representing 86% of total capital expenditures

Targets related to climate change mitigation and adaptation

Science-Based Target (SBTi-validated)

Target metric: Carbon intensity – CO₂ emissions in grammes of CO₂ per revenue tonne-kilometre (RTK) for passenger and freight transport

Target value: Reduction of 30.6% compared to baseline

Target year: 2030

Baseline year: 2019

Baseline value: Not explicitly disclosed in grammes CO₂/RTK

Scope: Scope 1 and Scope 3 Category 3 (fuel and energy-related activities not in Scope 1 or 2), covering aircraft operations worldwide

Type: Intensity-based target

Validation: Science-Based Targets initiative (SBTi) validated in 2022. First airline group in Europe and second worldwide with scientifically verified CO₂ reduction target aligned with Paris Climate Agreement 2015.

Progress to date (2024):

• Overall reduction in carbon emissions per RTK: 3.8% compared to 2019 base year
• Contributing factors:
  • Fleet renewal contribution: 15% (projected reduction based on current framework conditions)
  • Operational efficiency measures: 3.8% (projected reduction)
  • Sustainable aviation fuel (SAF) use: 3.4% (projected reduction)

Note: Progress was impacted by delays in aircraft deliveries preventing planned fleet renewal and geopolitical situations requiring flight detours with increased fuel consumption.

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Net Emissions Reduction Target

Target metric: Net CO₂ emissions (absolute)

Target value: 50% reduction compared to baseline

Target year: 2030

Baseline year: 2019

Baseline value: Not explicitly disclosed in absolute tonnes

Scope: Aircraft operations (includes voluntary carbon offsets beyond SBTi target)

Type: Absolute target (net)

Validation: Internal target (complements SBTi target)

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Carbon Neutrality Target

Target metric: Net-zero carbon emissions

Target value: Carbon neutral operations

Target year: 2050

Baseline year: 2019 (referenced)

Scope: Aircraft operations

Type: Absolute net-zero target

Validation: Internal target, aligned with IPCC goal to limit global warming to 1.5°C

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Ground Operations Renewable Energy Target

Target metric: Electricity sourcing from renewable energies

Target value: 100% renewable electricity

Target year: Not specified (part of long-term strategy through 2045)

Baseline year: Not disclosed

Scope: Ground operations in Germany, Austria and Switzerland (DACH region)

Type: Absolute target (market-based Scope 2 emissions)

Validation: Internal target

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Ground Mobility Carbon Neutrality Target

Target metric: Carbon neutrality in ground mobility

Target value: Carbon neutral ground mobility

Target year: 2030

Baseline year: Not disclosed

Scope: Ground mobility in DACH region

Type: Absolute net-zero target

Validation: Internal target (not sector-specific pathway verified)

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Ground Operations Carbon Neutrality Target

Target metric: Carbon neutral ground operations

Target value: Carbon neutral operations

Target year: 2045

Baseline year: Not disclosed

Scope: All ground operations (buildings, vehicle fleet, energy use)

Type: Absolute net-zero target

Validation: Internal target

Energy consumption and mix

Total energy consumption

The Lufthansa Group's total energy consumption in 2024 was 110,679,319 MWh (2023: not disclosed), covering flight operations, engine test rigs, Lufthansa Aviation Training, buildings, and the vehicle fleet across all CSRD-relevant companies.

Disaggregated energy mix (2024)

Energy intensity (high climate impact sectors)

For the high climate impact sectors (Passenger Airlines NACE H 51.10, Logistics H 51.20, and MRO C 33.16), energy intensity in 2024 was 2.7 kWh per euro of revenue.

Formula: Energy consumption from high climate impact sectors / segment revenue in high climate impact sectors.

Methodology and scope

Flight operations (kerosene): Direct measurement of kerosene consumption at flight level for all Passenger Airlines and Cargo flights. Tonnes converted to MWh using lower heating value factors from ISO 14083.

Sustainable aviation fuel (SAF): Volume sold from B2B and B2C channels reported centrally, converted to MWh using ISO 14083 lower heating values. Included in category (7) renewable fuel consumption.

Engine test rigs: Direct reading of kerosene consumption at Lufthansa Technik sites.

Lufthansa Aviation Training: Kerosene consumption from training flights based on invoices.

Buildings: Energy consumption calculated from Lufthansa Group energy costs and current energy prices (actual January–September, forecast October–December). Covers over 61% of electricity, 84% of gas, 59% of district heating/cooling, and 68% of heating oil consumption in the Group. Previous year figures used for remaining percentages. Gas and heating oil converted to MWh using ISO 14083 and BAFA (German Federal Office for Economic Affairs and Export Control) factors.

Vehicle fleet: Estimated energy consumption for key Lufthansa Group sites based on average kilometres travelled, consumption, and drive types. Covers most vehicles in Passenger Airlines segment and large portion of apron vehicles at hubs (65% diesel, 85% petrol, 100% gas and electricity). Previous year figures with risk premium used for remaining vehicles. Diesel and petrol converted to MWh using ISO 14083 factors.

All companies identified as relevant for CSRD reporting were included. Review confirmed no operational control over joint ventures or joint operations per ESRS E1 Paragraph 46.

External validation: Energy data validated by audit company Müller-BBM.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1: Direct GHG emissions

Lufthansa Group does not disclose a headline Scope 1 figure in the extracts provided. The company primarily reports specific CO₂ emissions per passenger-kilometre and total carbon emissions from flight operations (own and wet-leased aircraft) as operational metrics.

Specific CO₂ emissions per passenger-kilometre (grammes CO₂e/pkm):

Note: This metric covers direct emissions from flight operations normalised by passenger-kilometres.

Scope 2: Indirect GHG emissions from purchased energy

No Scope 2 figures (location-based or market-based) are disclosed in the extracts provided.

Scope 3: Indirect GHG emissions from value chain

No Scope 3 emissions by GHG Protocol category are disclosed in the extracts provided.

Total GHG emissions

The company does not disclose a consolidated total GHG emissions figure (Scope 1+2+3) in tCO₂e in the extracts provided.

GHG intensity

As noted above, the company reports specific CO₂ emissions per passenger-kilometre of 87.5 g CO₂e/pkm in 2024 (2023: 88.7 g CO₂e/pkm).

No revenue-based intensity metric (e.g. tCO₂e per million EUR revenue) is disclosed in the extracts provided.

Regulated emissions (EU ETS)

The report notes that costs of EU ETS certificates increased year-on-year by EUR 134 million in 2024, primarily because free allocations were discontinued. However, no total volume of regulated emissions (tCO₂e under EU ETS) is disclosed in the extracts provided.

Biogenic CO₂ emissions

No biogenic CO₂ emissions are disclosed separately in the extracts provided.

Methodology and scope notes

• The specific CO₂ emissions metric covers direct emissions from flight operations (own and wet-leased aircraft) normalised by revenue passenger-kilometres.
• The company references its validated Science Based Targets initiative (SBTi) target to cut CO₂ emissions per revenue tonne-kilometre by 30.6% by 2030 compared with 2019, but absolute emissions data for Scope 1, 2, and 3 are not presented in these extracts.
• The company states it aims to cut net carbon emissions in half by 2030 compared with 2019 and supports carbon neutrality by 2050, but quantified baseline and target-year absolute emissions are not disclosed in the extracts.
• EU ETS cost impacts are reported, but the underlying volume of emissions under the EU ETS is not quantified in the extracts.

Financial Effects from Climate-Related Impacts and Opportunities

Material Financial Impacts from Regulatory Changes:

EU Emissions Trading System (EU-ETS):

• EU ETS certificate costs increased by EUR 134m in 2024, primarily due to discontinued free allocations
• Gradual reduction of total emissions certificates with complete abolition of free allocations from 2026
• Risk of increasing displacement of long-haul connections to hubs outside Europe, distorting competition

Sustainable Aviation Fuel Requirements:

• European blending quotas for sustainable aviation fuel (ReFuelEU Aviation) expected to result in significant competitive disadvantages and steep cost increases
• SAF costs significantly higher than conventional fuel, with limited contingent of emissions certificates providing insufficient offset

Expected Future Cost Increases: The Lufthansa Group envisages significant cost increases over the next few years, particularly due to:

• Sustainability-related expenses arising on regulatory grounds (SAF quota, loss of free emissions certificates)
• Other cost increases in taxes, fees and charges
• Staff costs and material cost inflation
• Unit costs expected to remain under pressure due to ongoing cost inflation

Strategic Response and Investment Requirements:

Fleet Modernisation Investments:

• Extensive investments in fleet modernisation with latest-generation aircraft
• New aircraft deliver up to 30% lower fuel consumption and carbon emissions
• 242 aircraft on order (2025-2032) plus 182 options
• Sale-and-lease-back transactions: 15 short- and medium-haul aircraft in reporting year

Operational Efficiency Measures:

• Turnaround programme at Lufthansa Airlines targeting EUR 2.5bn earnings impact by 2028
• Group-wide efficiency and earnings improvement programmes
• Focus on reducing fixed cost base and making cost structure more variable

Revenue and Pricing Strategy:

• Need to increase unit revenues through targeted revenue-increasing measures
• Ongoing capacity restrictions expected to stabilise market yields
• Careful balance between market share growth, yield optimisation, and capacity allocation

Climate-Related Opportunities:

Premium Positioning for Sustainability:

• Introduction of Green Fares including carbon offsets rolled out to all long-haul flights
• Sustainable aviation fuel (SAF) offerings for customers
• Enhanced environmental commitment supporting premium market position

Operational Efficiencies:

• Modern fleet providing cost advantages through fuel efficiency
• Reduced maintenance costs and operational irregularities
• Long-term competitiveness through environmental leadership

Market Positioning:

• First airline group in Europe and second worldwide with SBTi-validated CO2 reduction target
• Leading position in sustainability may provide competitive advantages
• Alignment with customer demand for more sustainable travel options

Policies related to pollution

Deutsche Lufthansa does not disclose a specific named policy dedicated to pollution in the excerpts provided. However, the company describes its five-pillar strategy for active noise abatement as its approach to managing pollution impacts, specifically noise pollution.

Five-pillar strategy for active noise abatement

Since 2001, the Lufthansa Group has participated in research projects and implements noise abatement measures which are coordinated with relevant stakeholders. This research and development work is the basis for the Lufthansa Group's active noise abatement. It contributes significantly to optimising both fleet and flight operations. Such measures reduce noise emissions at the source and help relieve local residents in airport regions by better distributing the remaining noise.

The five pillars are:

• Investments in quieter aircraft
• Noise abatement technologies for the existing fleet
• Participation in noise research
• Development of optimised flight procedures and routes
• Dialogue with local residents and other stakeholders

Scope: The five-pillar strategy includes both generally effective and local activities – such as maintaining dialogue with stakeholders at key airports. Affected stakeholders include system partners such as airports, air traffic control organisations, local municipalities, dialogue platforms, noise committees, other airlines, and researchers in this field.

Key principles: With this five-pillar strategy, the Lufthansa Group focuses on reducing the negative impacts of noise on local communities and other stakeholders. The concept aligns with the international framework of the so-called Balanced Approach of the International Civil Aviation Organization (ICAO), which is applied at selected airports and is part of EU Regulation 598/2014 on the establishment of rules and procedures with regard to the introduction of noise-related operating restrictions at EU airports within a balanced approach.

Governance: The Lufthansa Group has a multi-airline expert committee under the direction of the Regulatory Affairs Infrastructure department, which meets regularly to discuss current operational and technical developments on the topic of active noise abatement. The department is the central point of contact and representative for the Human Resources & Infrastructure Executive Board function in relation to airports, air traffic control, handling agents, regulatory and political institutions (e.g. ministries) and industry associations. As the central coordinating unit within the Group on the issue of aircraft noise, it represents the Lufthansa Group in the committees of the "Forum Flughafen und Region" in Frankfurt and supports the Lufthansa Group's participation in various aircraft noise committees.

Stakeholder engagement: Participation in various local committees, dialogue platforms, and expert working groups forms an integral part of the five-pillar strategy. Dialogues with stakeholders occur particularly at the Lufthansa Group's hubs.

Note on scope limitations: Incidents and emergency situations are not considered relevant for active noise abatement. Consequently, the Lufthansa Group's policies do not cover the prevention of such events.

Actions and resources related to pollution

Overview

Measures to reduce aircraft noise aim to reduce the noise generated directly by the aircraft. The Lufthansa Group seeks to better understand which activities can contribute to reducing noise pollution. Some measures affect every flight globally, while others are specifically tailored to individual sites. The measures described are implemented continuously with no fixed time horizons, except for research and development projects which typically span between one and five years.

Action 1: Fleet modernisation with modern and quieter aircraft

Description: Fleet renewal is the highest priority measure for reducing aircraft noise at source. The Lufthansa Group updates its fleet continuously with aircraft that have modern engines and are much quieter than comparable older aircraft types.

Scope: Own operations

Time horizon: Continuous, ongoing

Resources allocated:

• Financial: EUR 3,912m invested in fleet renewal in 2024
• The capital expenditure is taxonomy-eligible and reported under Activity 6.19 Passenger and freight air transport within Environmental Objective 1 – Climate change mitigation

Outcomes:

• 18 new aircraft added in 2024: Airbus A320neos, A321neos, A350-900s and Boeing 787-9s
• Four aircraft removed from Group fleet
• Since 2019, the proportion of fleet fitted with latest technology more than doubled to 22% (158 aircraft)
• Expected delivery of approximately 30 state-of-the-art aircraft in 2025
• Order backlog comprises around 240 aircraft featuring the latest technology
• Newly commissioned aircraft meet ICAO noise requirements

Action 2: Retrofitting existing fleet with noise-reducing vortex generators

Description: Technical modification of existing fleet with noise-reducing vortex generators on Airbus A320 family aircraft.

Scope: Own operations

Time horizon: Continuous, completed for most airlines by end of 2024

Resources allocated:

• Carried out during routine technical maintenance cycles

Outcomes:

• In 2014, Lufthansa Airlines became first airline worldwide to operate with new Airbus A320 equipped with noise-reducing vortex generators
• Aircraft with vortex generators are up to four decibels quieter on approach
• Lower noise fees paid in Frankfurt compared to aircraft without these components
• All A320 family aircraft at Lufthansa Airlines and SWISS now fitted
• Austrian Airlines completed retrofitting of six A320 aircraft by end of 2024
• Eurowings equipped all A320-family aircraft with vortex generators since end of 2023, entire fleet consistently fitted in 2024

Action 3: AeroSHARK functional surface coating

Description: Technical measure to reduce air resistance and kerosene consumption using "riblet films" (microscopically small ribs modelled on shark skin), developed by Lufthansa Technik together with BASF.

Scope: Own operations

Resources allocated:

• Non-financial: Partnership with Lufthansa Technik and BASF

Outcomes:

• Reduces air resistance and kerosene consumption by around 0.8%
• At end of 2024, 17 Boeing 777s fitted with AeroSHARK in service:
  • 12 Boeing 777-300ERs at SWISS
  • 5 Boeing 777Fs at Lufthansa Cargo

Action 4: Participation in Low Noise Augmentation System (LNAS) research

Description: Support for German Aerospace Center in developing LNAS for optimising approaches and take-offs. LNAS uses aircraft data to recommend optimal configuration and speed for quieter and more efficient approaches and take-offs.

Scope: Own operations (research collaboration)

Time horizon: Research and development project (typically 1-5 years)

Resources allocated:

• Non-financial: Partnership with German Aerospace Center
• Provision of large amount of flight data and additional information

Outcomes:

• Lufthansa Airlines supported development of new LNAS departure functionality
• Improved LNAS approach capabilities in reporting year
• Practical testing of new functionality planned on Lufthansa Airlines A330 fleet
• Preparations for testing began in reporting year

Action 5: Optimised flight procedures and flight routes

Description: Optimising vertical flight profile (flight procedures) and horizontal flight management (flight routes) to reduce noise, in cooperation with system partners including German air traffic control (DFS) and international partners.

Scope: Own operations and infrastructure partnerships

Time horizon: Continuous, ongoing

Resources allocated:

• Non-financial: Cooperation with DFS and international partners
• Active participation in "Forum Flughafen und Region" Active Noise Abatement expert panel and sub-working groups

Outcomes:

• Modern satellite-based Required Navigation Performance (RNP) technology implemented
• New RNP departure route in Stuttgart continued after first operational year analysis (summer 2024)
• Study on take-off procedures published September 2024 found Lufthansa Airlines procedure for Frankfurt generates less noise than other methods

Action 6: Stakeholder engagement and dialogue

Description: Participation in various local committees, dialogue platforms, and expert working groups at key airports, particularly at Lufthansa Group's hubs.

Scope: Own operations and value chain (airports, local communities)

Time horizon: Continuous, ongoing

Resources allocated:

• Non-financial: Multi-airline expert committee under Regulatory Affairs Infrastructure department
• Participation in flight noise committees at major airports
• Involvement in Alliance for Aircraft Noise Protection at Hamburg location
• Membership in working group of German flight noise committees

Outcomes:

• Regular meetings to discuss current operational and technical developments
• Compliance with ICAO Balanced Approach framework (EU Regulation 598/2014)
• Stakeholder engagement with airports, air traffic control, municipalities, dialogue platforms, noise committees

Targets related to pollution

Aircraft Noise Reduction Target

Target description: The Lufthansa Group is committed to continuously reducing aircraft noise. The primary goal is to lower aircraft noise at source and to develop optimised flight procedures together with system partners.

Target metric: Aircraft noise reduction

Scope: Own operations (flight operations)

Approach:

• Active participation in the Alliance for Active Noise Abatement at Frankfurt location since 2012
• Collaboration with stakeholders in the "Forum Flughafen und Region" to monitor effectiveness of active noise abatement measures
• Implementation of noise-reducing aircraft modifications, such as vortex generators
• Fleet modernisation

Monitoring: As of 28 October 2024, 99.6% of the aircraft – virtually the Group's entire operating fleet – met noise reduction criteria.

Note: The disclosure describes a commitment to continuous reduction but does not specify a quantified target value, baseline year, or target year for aircraft noise reduction.

Pollution of air, water and soil

Active noise abatement metric

As of 28 October 2024, 99.6% of the aircraft – virtually the Group's entire operating fleet – met the "minus-ten-decibel criterion" set by the ICAO Chapter 4 standard.

This standard requires that all aircraft cumulatively fall below the ICAO Chapter 3 noise limits by a margin of ten decibels or more.

Methodology:
The Corporate Responsibility – Emissions Management department requests noise certificates from the maintenance organisations, compares the noise data for the aircraft with the noise limits defined by the ICAO in Chapter 4 of the Chicago Convention and determines the active noise abatement metric on this basis. The calculation is precise with low measurement uncertainty.

Other pollutants

The Lufthansa Group states that ESRS E2-4 requires disclosure of the amount of each pollutant listed in Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil. However, no quantified emissions data for NOx, SOx, SO2, PM, VOC, heavy metals, nutrients, BOD/COD, microplastics or other E-PRTR pollutants are disclosed in the provided excerpts.

The reporting focuses primarily on aircraft noise as the material pollution impact for the aviation industry.

Anticipated financial effects from pollution-related impacts, risks and opportunities

Phase-in exemption

The Lufthansa Group is making use of the option available under ESRS 1 Paragraph 137 to omit the disclosures required under ESRS E2-6 in the first year of preparation of its non-financial statement.

Policies related to resource use and circular economy

The Lufthansa Group regards the R-strategies that systematically prioritise efforts to reduce, reuse, recycle, recover and replace materials as the model for its resource use and circular economy activities. These are introduced by the individual business segments in various ways.

Lufthansa Group Passenger Airlines: Global waste policies

Based on the R-strategies and the EU's waste hierarchy (2008/98/EC), the Lufthansa Group Passenger Airlines segment has introduced specific guidelines under the framework of its global waste policies with the aim of promoting the shift away from the use of primary resources and towards renewable, recycled or recyclable materials.

Key content and principles:

• In respect of single-use plastic packaging in particular, the airlines are increasingly using materials from renewable and recyclable resources for items such as single-use cutlery and headphone and blanket packaging
• Steps are being taken to ensure that products that are made from a single material and can be recycled are used where possible going forward
• Lufthansa Airlines, SWISS, Austrian Airlines and Air Dolomiti are revising their tenders to state that they only intend to source materials that do not end up in landfill but are instead used for recycling

Scope: The waste targets policy relates to single-use waste, food waste and reusable waste in the Lufthansa Group Passenger Airlines segment and the lounges that come under this.

Governance:

• The Lufthansa Group Corporate Responsibility and product management departments are jointly responsible for management and coordination, conceptual work, target setting and monitoring at Group level in respect of in-flight waste
• To ensure Group-wide integration, a working group made up of Lufthansa Group's Passenger Airlines representatives has been established to regularly discuss the progress made and challenges faced and to draw up joint standards

Framework for in-flight waste: The passenger airlines of the Lufthansa Group have jointly defined a framework for dealing responsibly with in-flight waste, covering every aspect of it. In-flight waste is divided into three categories:

• Single-use waste: materials that become waste after being used once in-flight or after a flight event, without any defined recycling processes
• Food waste: may arise both during and after flights
• Reusable waste: materials that are already part of a circular system, but later become waste without any downstream recycling processes

Implementation: Since 2023, the Lufthansa Group Passenger Airlines have implemented the R-strategies:

• Reduce: services, such as providing headphones on request to reduce single-use plastic
• Reuse: use of reusable products, such as reusable cups
• Recycle: use and collection of certain plastics for recycling
• Recover: implementation of a process for transferring beverage residue to a biogas plant
• Replace: switch from plastic to paper packaging

Lufthansa Technik: Maintenance and circular economy approaches

Within its main business activity – the maintenance of aircraft and aircraft parts, such as components, engines and landing gear – Lufthansa Technik is guided by the requirements of original equipment manufacturers (OEMs), which set out in detail the permitted parts and repair procedures.

Regulatory framework:

• As a maintenance organisation, Lufthansa Technik is obliged to operate in compliance with the requirements of European Union Aviation Safety Agency (EASA) Part-145 governing aircraft maintenance and other safety regulations
• Lufthansa Technik is therefore not responsible for decisions on the use of recycled materials
• The Company sources its materials and parts exclusively from certified suppliers that guarantee the required quality standards

Governance:

• Segment and site management are responsible for the implementation
• Individual Lufthansa Technik sites develop their own approaches and define measures to ensure Lufthansa Technik achieves its group-wide aim of increasing the recycling rate to 75%

Circular economy approaches: Lufthansa Technik applies the circular economy R-strategies in various processes within its repair and maintenance services:

• The leasing of spare parts and other replaceable aircraft components to airlines helps to keep inventories low and materials in economic circulation for longer
• The use of parts from retired aircraft following maintenance and certification supports the principle of reuse
• Materials such as steel from retired aircraft are sent for recycling

Lufthansa Cargo: Circular economy concept

Lufthansa Cargo pursues a circular economy concept aimed at avoiding and reducing the use of resources as well as conserving resources. This includes loading aids and equipment that are indispensable in the airfreight transport sector.

Key principles:

• Increasing recycling rates by substituting materials, introducing closed-loop systems and conserving resources
• Increasing resource efficiency by reducing the materials used
• Maximising reusability within the framework of existing regulations
• Implementing upcycling projects with individual materials

Scope: The policy covers all cargo capacity on both cargo and passenger airlines of Lufthansa Airlines, Austrian Airlines, Brussels Airlines, Discover Airlines and SunExpress as well as onward ground transport by truck. Where service providers take care of cargo handling operations, compliance with requirements for the promotion of the circular economy is maintained through contractual agreements.

Governance:

• Experts in the Environmental Management and Corporate Responsibility, Logistics Procurement and Global Fulfilment Management departments are responsible for the circular economy policy
• Internal employees are involved, along with manufacturers, suppliers, handling partners and local institutions such as vocational and training centres

Implementation: Compliance with and implementation of the circular economy policy is ensured by examining the technical specifications for materials and by ensuring that suppliers adhere to purchasing requirements.

Public availability: More details on the circular economy policy are available on the Lufthansa Cargo website.

Actions and resources related to circular economy

Lufthansa Group Passenger Airlines

Scope: Own operations (in-flight and procurement)

Time horizon: Short-term (2024-2025)

Replace: expedite the replacement of single-use materials

• Focus: Replacing single-use plastic and single-use aluminium in procurement process
• Procurement department sources renewable and recyclable materials wherever possible

Specific replacement actions implemented in 2024:

• Bagasse trays trial (Lufthansa Airlines and Edelweiss Air): Successfully trialled replacing single-use aluminium trays with bagasse trays (sugarcane byproduct) in Economy Class; further opportunities to be explored in 2025
• SWISS paper cutlery packaging: Since June 2024, using paper rather than plastic packaging for cutlery in Economy Class
• Blanket packaging replacement (Austrian Airlines, Brussels Airlines, Lufthansa Airlines, Discover Airlines): Replaced plastic blanket packaging with paper sleeves
• SWISS reusable cups trial: Trialled reusable cups rather than single-use plastic cups on various flight segments in 2024; plans to introduce reusable cups across the board from 2025
• Air Dolomiti steel cutlery: Replaced single-use plastic cutlery for crews with steel cutlery, reducing unsorted waste
• Discover Airlines meal service: Now using trays and items that enable meal service without any single-use plastic or aluminium
• Lufthansa Airlines headphones: Introduced new, higher-quality headphones in Economy Class to encourage customers to take them and re-use them
• Paper headphone packaging (Austrian Airlines, SWISS, Brussels Airlines): Using paper rather than plastic packaging for headphones

Reduce: cut resource use and analyse waste streams

On-demand services introduced in 2024:

• SWISS First Class: Amenity kit items offered solely through service staff
• Lufthansa Airlines: Only distributes headphones to customers that request them
• Various airlines: Butter and salad dressings provided as necessary on various flight segments
• Austrian Airlines long-haul load reduction: Reduced load of milk (by 20%), cream (by 30%) and bread (by 45%) on long-haul flights
• Brussels Airlines dry ice packaging: Using less packaging for dry ice

Recycle: recycle materials

• Airline-specific recycling policies introduced for crews on all passenger airlines
• SWISS recycling expansion: Launched several initiatives in 2024; now recycles greater volumes in the United States; expanded in-flight recycling of textiles to include First Class pyjamas; recycling packaging from composite materials at Zurich hub
• Eurowings Dusseldorf trial: Conducted recycling trials at Dusseldorf Airport with partners and local cleaning company, resulting in 420 kilograms of recyclable materials sent for recycling
• Austrian Airlines textile recycling: Recycled 1,620 kilograms of textiles in 2024; introduced new textile recycling process already in use at SWISS

Expected outcomes:

• 2025 target: No single-use plastic or single-use aluminium items on flights from 2025 onwards (covers all single-use in-flight items used directly by customers)
• Food waste reduction target: Reduce volume of food waste on short-haul flights by 50% compared with 2019 by 2025
• Food waste on long-haul: Working with catering partners to improve data transparency; corresponding targets planned from 2026
• Reusable waste target: Plans to define target for 2026 onwards; eight beacon projects planned in the meantime
• Progress monitoring: 263 of 731 single-use plastic and single-use aluminium items replaced to date (2024)

Quantitative targets: To be established through planned goal-setting process in 2025, effective from 2026 onwards

Links to policy: Actions based on R-strategies defined in E5-1 circular economy policy; aligned with Circular Economy Action Plan (part of European Green Deal)

Lufthansa Cargo

Scope: Own operations (air transport services, cargo hubs Frankfurt and Munich)

Time horizon: Short-term (2023-2025)

Resource efficiency actions

• Plastic film with recycled content: Since January 2023, plastic film used worldwide has 10% share of recycled material
• Lightweight net for small pallets: New net introduced in 2023, around 10 kilograms lighter than previous nets; feasibility of use with larger pallets to be examined in 2025
• Extended use of equipment: All containers, pallets, nets, boards and straps used until expiry date or no longer fit for use
• Boards as energy source: Boards no longer usable are utilized as energy source at Frankfurt site
• Lightweight containers: Using fibre-reinforced composite containers instead of aluminium to save kerosene and reduce carbon emissions; focus on optimising useful life in compliance with IATA regulations
• Biodegradable load-securing film trial: Trialling biodegradable film for securing loads (2024)

Stakeholders involved: Manufacturers, suppliers, waste disposal companies, own employees, local vocational and training centres, IATA sustainable working groups

Implementation: Through contractual agreements worldwide and internal initiatives, particularly at largest cargo hubs in Frankfurt and Munich

Expected outcomes:

• Target: Increase share of recycled materials to 40% by end of 2025 (all materials disposed at Frankfurt hub)
• Baseline (2020): 35% recycled materials
• 2023 progress: 38% recycled materials
• 2024 values: Not yet available at time of report release

Monitoring: Progress reviewed annually based on local waste balance from waste disposal company; framework agreement signed with waste disposal company in Frankfurt and Munich

Links to policy: Implements R-strategies from circular economy policy; requirements set in supplier contracts

Responsibility: Environmental Management and Corporate Responsibility, Logistics Procurement and Global Fulfilment Management departments

Lufthansa Technik

Scope: Own operations (production sites)

Time horizon: Medium-term (2017-2025 target period)

Recycling rate increase

• Target: Increase recycling rate to 75% by 2025
• Baseline (2018): 51% recycling rate
• 2024 performance: 57% recycling rate (6% year-on-year increase)
• Target review: Plans to reevaluate targets and time horizons in 2025

Adopted by: Segment management, Executive Board and Lufthansa Technik's environmental department (2017)

Links to policy: Voluntary target, not based on legal obligations

Note on circular product design: Very limited scope for development due to EASA Part-145 regulations requiring certified suppliers; no direct influence over circular design principles in aircraft materials and components; therefore no circular product design targets defined

Resources allocated

Non-financial resources:

• Procurement department personnel (Passenger Airlines)
• Environmental Management, Corporate Responsibility, Logistics Procurement and Global Fulfilment Management departments (Cargo)
• Environmental department (Technik)
• Partnerships with catering partners, waste disposal companies, local cleaning companies, vocational training centres
• Industry engagement through IATA sustainable working groups (Cargo)
• Service providers bound by contractual agreements (Cargo)

Financial resources: Not quantified in disclosure

Targets related to circular economy

Passenger Airlines Segment

Single-use plastic and aluminium elimination

• Target: No single-use plastic or single-use aluminium items on flights
• Target year: 2025 onwards
• Scope: All single-use in-flight items used directly by customers in Passenger Airlines segment (excludes items such as rubbish bags)
• Baseline year: Not specified
• Type: Absolute (qualitative elimination target)
• Validation: Voluntary target (expected to become mandatory in 2030 under EU PPWR and SUP directives)
• Progress to date: As of 2024, 263 out of 731 single-use plastic and single-use aluminium items have been replaced

Food waste reduction on short-haul flights

• Target: Reduce food waste by 50% (by weight)
• Target year: 2025
• Baseline year: 2019
• Scope: Short-haul flights in Passenger Airlines segment
• Type: Absolute (percentage reduction)
• Validation: Voluntary target
• Progress to date: Not disclosed in numerical terms

Food waste on long-haul flights

• Target: Minimise food waste (qualitative)
• Target year: Targets to be adopted from 2026 onwards
• Baseline year: Not yet established
• Scope: Long-haul flights
• Status: Data quality improvement in progress with catering partners

Reusable waste

• Target: To be defined for 2026 onwards
• Interim action: Eight beacon projects planned
• Scope: Passenger Airlines segment and lounges

Circular principles for reusable waste

• Target: Introduce circular principles for reusable waste (qualitative)
• Target year: Not specified
• Scope: Passenger Airlines segment and lounges

Lufthansa Technik Segment

Recycling rate increase

• Target: 75% recycling rate
• Target year: 2025
• Baseline year: 2018
• Baseline value: 51%
• Progress to date: 57% in 2024 (6% year-on-year increase)
• Type: Absolute (percentage)
• Scope: Lufthansa Technik sites
• Validation: Voluntary target
• Status: Plans to reevaluate targets and time horizons in 2025

Lufthansa Cargo Segment

Recycled materials share increase

• Target: 40% share of recycled materials
• Target year: End of 2025
• Baseline year: 2020
• Baseline value: 35%
• Progress to date: 38% in 2023 (2024 values not yet available at time of Annual Report release)
• Type: Absolute (percentage)
• Scope: All materials disposed of at Lufthansa Cargo's Frankfurt hub
• Validation: Voluntary target

Notes on target governance

• Quantitative targets for repurposing recyclable waste: To be defined in planned goal-setting process in 2025, effective from 2026 onwards (Passenger Airlines)
• EU regulatory context: Current targets are voluntary; expected to become mandatory in 2030 under EU Packaging and Packaging Waste Directive (PPWR) and Single-Use Plastics Directive (SUP)
• Lufthansa Technik limitations: No circular product design targets due to EASA Part-145 regulatory requirements limiting influence over material use; no targets for leasing-based repair services impact on resource use

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Phase-in exemption

The Lufthansa Group is making use of the option available under ESRS 1 Paragraph 137 to omit the disclosures required under ESRS E5-6 in the first year of preparation of its non-financial statement.

Own Workforce Policies

Human Resources Management Strategy The Lufthansa Group's employees play an indispensable role in its success. Human resources management was a key pillar for building the future of the Lufthansa Group in 2024. The Company's corporate culture remains of key significance, with the commitment and well-being of the workforce being main priorities alongside financial success.

Corporate Culture Development The Lufthansa Group aims to further enhance its corporate culture with its current Cultural Journey programme to meet the changing requirements of society, its workforce and shareholders. This cultural programme brings together values such as diversity, respect and individual development opportunities. The development of the Lufthansa Group's corporate culture is driven by a Group-wide initiative to promote cooperation between all Group companies and business segments.

Comprehensive HR Approach The Lufthansa Group pursues a comprehensive approach which ensures:

• Equal opportunity and promotion of diversity
• Professional training and development
• Work-life balance
• Partnership-based and transparent corporate culture
• Flexible career paths

This supports the Company's goal of being an attractive employer while promoting and retaining talent on a long-term basis.

Employee Engagement and Feedback The Company-wide employee survey "involve me!" helps to identify strategic areas of action in a targeted manner and to integrate these within the Group's HR strategy.

Attractive Working Environment In terms of responsibility for its employees, the Lufthansa Group attaches great importance to offering its staff an attractive working environment with:

• Transparent structures
• Efficient processes
• Wide range of social benefits
• Extensive opportunities for ongoing development
• Strong position as an employer within the aviation industry

Training and Development The Lufthansa Group offers its employees extensive opportunities for their ongoing development, contributing to employee satisfaction and safeguarding jobs. At year-end, 1,860 apprentices were in training for around 30 occupations and various combined degree courses offered by the Lufthansa Group worldwide (previous year: 1,640).

Diversity and Equal Opportunity Diversity and equal opportunity are seen as a strength within the organization, forming part of the comprehensive approach to human resources management.

Processes for Engaging with Own Workforce

Employee Survey Programme The Company-wide employee survey "involve me!" serves as the primary mechanism for engaging with the workforce. This survey helps to identify strategic areas of action in a targeted manner and integrate these within the Group's HR strategy.

Collective Bargaining and Social Dialogue The Lufthansa Group maintains extensive engagement with employee representatives through collective bargaining processes. In the 2024 financial year, the Group reached a large number of new pay settlements with its collective bargaining partners.

Key Collective Bargaining Achievements in 2024:

Germany:

• Ground Staff: AGVL and ver.di signed agreement for ~20,000 ground staff including Deutsche Lufthansa AG, Lufthansa Technik AG and Lufthansa Cargo AG
• Cabin Crew: AGVL and UFO signed wage agreement for ~19,000 cabin crew at Lufthansa Airlines with 3-year minimum term
• Discover Airlines: Framework and wage agreement with ver.di for entire cabin crew, cannot be terminated until 31 December 2027

Austria:

• Austrian Airlines: New collective agreement for ~2,400 flight attendants and ~1,000 pilots running until December 2026
• Commercial and Technical Staff: Wage settlement including inflation bonus and apprentice remuneration adjustments

Belgium:

• Brussels Airlines: New wage agreements for both pilots and cabin crew running until end of 2026

Other Airlines:

• Eurowings: Multiple agreements with VC trade union for pilots and ver.di for cabin crew and ground staff
• Edelweiss: New collective agreement for pilots effective January 2025

Conflict Resolution Mechanisms Agreements include conflict resolution mechanisms such as mediation and arbitration, forming core aspects of workforce engagement frameworks.

Social Partnership Approach Within the scope of its social and collective bargaining policies, the Lufthansa Group aims to define good working conditions and fair salary arrangements which strike a balance between the interests of the companies and employees in every part of the Group. Longer-term agreements establish planning certainty for both parties.

Remediation Processes and Channels for Workforce Concerns

Collective Bargaining Framework The collective agreements concluded in 2024 include comprehensive frameworks for addressing workforce concerns and remediation processes.

Conflict Resolution Mechanisms Agreements with workforce representatives include specific conflict resolution mechanisms such as:

• Mediation processes
• Arbitration procedures

These mechanisms form core aspects of the collective bargaining agreements, particularly highlighted in the Discover Airlines agreement which "cannot be terminated until 31 December 2027" and includes "an agreement on conflict resolution mechanisms such as mediation and arbitration."

Ongoing Negotiations Framework UFO terminated the applicable framework agreement as of the end of 2024, with negotiations on working conditions for cabin crew likely to take place from 2025 onwards, demonstrating the ongoing nature of workforce dialogue and concern resolution.

Partnership-Based Corporate Culture The Company strives to achieve a partnership-based and transparent corporate culture that supports flexible career paths and provides mechanisms for addressing employee concerns through established social partnership approaches.

Long-term Agreements for Stability Many agreements have extended terms (3+ years) which provide stability and predictable frameworks for addressing workforce issues, with some agreements specifically designed to facilitate strategic planning while maintaining channels for ongoing dialogue.

Actions on Material Impacts and Managing Risks and Opportunities

Comprehensive Workforce Strategy Implementation

The Lufthansa Group has implemented comprehensive measures to address material workforce impacts and manage associated risks and opportunities:

Cultural Transformation Programme

• Implementation of the Cultural Journey programme to enhance corporate culture
• Focus on bringing together values such as diversity, respect and individual development opportunities
• Group-wide initiative to promote cooperation between all Group companies and business segments
• Addressing changing requirements of society, workforce and shareholders

Recruitment and Retention Measures

• Successful recruitment measures in operational areas resulting in workforce increase of 5,032 employees (5%) in 2024
• Targeted recruitment planned for 2025 to attract qualified and motivated employees with right skills
• Recruitment freeze in administrative areas while increasing personnel in operational and technical fields
• Focus on maintaining strong position as employer within aviation industry

Skills Development and Training

• 1,860 apprentices in training for around 30 occupations and various combined degree courses (increase from 1,640 in previous year)
• Extensive opportunities for ongoing development contributing to employee satisfaction
• Finance Academy launched as part of Finance Transformation Programme for professional training and talent development

Working Conditions Improvements

• Substantial salary adjustments across multiple employee groups:
  • Ground staff: average increases up to 12.5%
  • Cabin crew: increases of 16.5% over three years
  • Austrian Airlines: 19.4% increases in three phases
• Enhanced benefits packages including inflation bonuses, increased allowances, higher holiday pay
• Long-term agreements (3+ years) providing planning certainty

Work-Life Balance Measures

• 35% of employees work part-time (maintained from previous year)
• Flexible career paths supported through comprehensive HR approach
• Partnership-based and transparent corporate culture

Employee Engagement and Satisfaction

• Company-wide "involve me!" employee survey to identify strategic action areas
• Decreased fluctuation rate to 6% (from 7% previous year)
• Focus on commitment and well-being of workforce alongside financial success

Diversity and Equal Opportunity

• Diversity and equal opportunity seen as strength
• Comprehensive approach ensuring equal opportunity and promotion of diversity
• Support for disadvantaged people worldwide through help alliance aid organisation

Effectiveness Measures

Quantitative Indicators:

• Workforce growth of 5% demonstrating successful attraction and retention
• Reduced staff turnover (6% vs 7%) indicating improved satisfaction
• Increased apprenticeship intake (1,860 vs 1,640) showing commitment to development
• Maintained work-life balance metrics (35% part-time unchanged)

Strategic Positioning:

• Enhanced position as attractive employer in aviation industry
• Benchmark against large German companies for employment standards
• Long-term stability through multi-year collective agreements
• Integration of workforce strategy with overall business transformation

Risk Management:

• Proactive approach to industrial relations through comprehensive bargaining
• Conflict resolution mechanisms including mediation and arbitration
• Planning certainty through longer-term agreements
• Balance between company interests and employee welfare

Targets related to own workforce

The Lufthansa Group derives its targets from both the Group strategy and its Human Resources strategy. Key performance indicators are iteratively developed and defined at the Group level by the responsible specialist departments, the strategy departments, and the Lufthansa Group Executive Board. The Group strategy department monitors these targets and reports on them to the Group Executive Board at regular intervals.

In most cases, the Lufthansa Group has established qualitative targets for these measures. However, a specific quantitative target has been set for female leadership, with a goal to be achieved by 2025.

Quantified targets

¹⁾ Women in management positions comprises the proportion of female managers in the Group Executive Board and the three subordinate management levels.

²⁾ This figure would be 2.2 according to the calculation method applied in the previous year.

Target characteristics

Women in management positions:

• Target metric: Percentage of women in management positions (Group Executive Board and three subordinate management levels)
• Target value: 25%
• Target year: 2025
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Progress to date (2024): 25.3%
• Scope: Group-wide
• Type: Not specified (appears to be absolute percentage)
• Validation: Internal target

Engagement index:

• Target metric: Employee engagement index value
• Target value: According to the benchmark (qualitative)
• Target year: Not specified
• Baseline year: Not disclosed
• Progress to date (2024): 3.8
• Scope: Not specified
• Type: Not specified
• Validation: Internal target

Characteristics of the Undertaking's Employees

Total Workforce At year-end 2024, the Lufthansa Group had 101,709 employees worldwide (previous year: 96,677), representing a year-on-year increase of 5,032 employees or 5%. This increase occurred despite the loss of around 1,250 employees due to the sale of AirPlus.

Full-Time Equivalent Translated into full-time positions, the Group had 84,215 employees at the end of 2024 (previous year: 80,583), representing a year-on-year increase of 3,632 or 5%.

Geographic Distribution

In Germany, the Group had 66,336 employees: 3,160 more than in the previous year (previous year: 63,176), representing a 5% increase. The number of employees outside Germany increased by 1,872 or 6% to 35,373 (previous year: 33,501).

Business Segment Distribution

Regional Distribution

Workforce Demographics

• Average age: 42.1 years (previous year: 42.6 years)
• Average seniority: 13.7 years (previous year: 14.2 years)
• Part-time workers: 35% of employees (unchanged from previous year)
• Fluctuation rate: 6% (previous year: 7%)

Training and Development

• Apprentices: 1,860 apprentices in training (previous year: 1,640)
• Training areas: Around 30 occupations and various combined degree courses offered worldwide

Historical Context The current workforce level represents a 26% decrease (36,644 fewer employees) compared to pre-crisis levels (31 December 2019: 138,353 employees).

Planned Changes Targeted recruitment measures are planned for the 2025 financial year to attract qualified and motivated employees with the right skills and abilities. Recruitment in administrative areas has been partially frozen, while the Group aims to continue increasing personnel in operational and technical fields.

Characteristics of Non-Employee Workers

Wet Lease Operations The airlines in the Lufthansa Group operated 56 aircraft on the basis of wet leases in the reporting year. The reasons behind this were:

• Making up for delayed aircraft deliveries
• Expanding capacities in the busy summer months
• Addressing capacity constraints from engine inspection requirements

Wet lease arrangements involve external airlines providing both aircraft and crew services, representing a significant form of non-employee work arrangement.

Engine Inspection Impact Potential material defects in components of the PW1100G engine family meant that parts concerned had to be inspected for safety reasons. An average of around 30 aircraft in the Lufthansa Group were therefore not available for service in the reporting year. The Group mitigated these effects through:

• Acquiring additional replacement engines
• Extending the useful life of existing aircraft
• Additional wet leases

This demonstrates the strategic use of non-employee workers (external crews) to maintain operational capacity during equipment unavailability.

Capacity Management Strategy The Group can modify capacity on offer through various flexible arrangements:

• Extending or shortening temporary decommissioning
• Delaying or bringing forward planned retirements
• Taking out wet leases to match stronger or weaker than planned demand

These arrangements provide operational flexibility while utilizing non-employee workers when internal capacity is insufficient or when market conditions require rapid capacity adjustments.

Collective Bargaining Coverage and Social Dialogue

Extensive Collective Bargaining Coverage In the 2024 financial year, the Lufthansa Group, represented by the relevant industry associations or its subsidiaries, reached a large number of new pay settlements with its collective bargaining partners, covering the majority of the workforce across different countries and employee groups.

Germany - Major Agreements:

Ground Staff Agreement (March 2024):

• Parties: Air Transport Employers' Federation (AGVL) and ver.di
• Coverage: ~20,000 ground staff including employees at Deutsche Lufthansa AG, Lufthansa Technik AG and Lufthansa Cargo AG
• Terms: Average wage increase up to 12.5% in two phases, inflation bonus, additional holiday benefits, special apprentice package

Cabin Crew Agreement (April 2024):

• Parties: AGVL and Unabhängige Flugbegleiter Organisation e.V. (UFO)
• Coverage: ~19,000 cabin crew at Lufthansa Airlines
• Terms: Gradual salary increases of 16.5% total, inflation bonus, increased allowances and holiday pay
• Duration: Minimum 3-year term for strategic planning certainty
• Note: UFO terminated framework agreement end-2024, negotiations on working conditions expected from 2025

Discover Airlines Agreement (August 2024):

• Parties: Discover Airlines and ver.di
• Coverage: Entire cabin crew
• Duration: Cannot be terminated until 31 December 2027
• Terms: Substantial salary structure adjustment, robust work/employment conditions, conflict resolution mechanisms (mediation/arbitration)

Eurowings Agreements:

• Pilots (July 2024): VC trade union, 3-year term, 17% total salary increases, inflation bonus
• Cabin Crew: ver.di agreement, 19 months, ~4% salary adjustments plus inflation bonus
• Ground Staff: Framework agreement with ver.di for Eurowings Aviation GmbH
• Technical Staff (September 2024): ver.di for Eurowings Technik GmbH, 3-year term, 15.7% total basic salary increases

Austria - Austrian Airlines:

• Flight Attendants & Pilots (April 2024): vida trade union
• Coverage: ~2,400 flight attendants and ~1,000 pilots
• Terms: Gradual salary increase of ~19.4% in three phases
• Duration: Until December 2026
• Additional: Separate agreement for commercial and technical staff with inflation bonus and apprentice remuneration adjustments from January 2025

Belgium - Brussels Airlines:

• Pilots: New agreement until end of 2026, average salary increases of 3.1%
• Cabin Crew: New settlement until end of 2026, average salary increases of 1.6%

Switzerland:

• Edelweiss Pilots: New collective agreement effective 1 January 2025

Social Dialogue Approach Within the scope of its social and collective bargaining policies, the Lufthansa Group aims to:

• Define good working conditions and fair salary arrangements
• Strike balance between company and employee interests across all Group parts
• Establish longer-term agreements for planning certainty for both parties
• Develop sustainable relationships with collective bargaining partners

Agreement Features:

• Long-term stability: Most agreements span 2-3 years
• Comprehensive coverage: Salary increases, benefits, working conditions
• Conflict resolution: Built-in mediation and arbitration mechanisms
• Inflation protection: Most agreements include inflation bonuses
• Strategic certainty: Longer terms facilitate strategic staff cost planning

Diversity Metrics

Diversity as Organizational Strength Diversity and equal opportunity are seen as a strength within the Lufthansa Group. The Company pursues a comprehensive approach which ensures equal opportunity and promotion of diversity as part of its human resources strategy.

Geographic Diversity The Lufthansa Group demonstrates significant geographic diversity in its workforce:

Regional Distribution of 101,709 Employees:

International Presence

• 35% of workforce (35,373 employees) based outside Germany
• Significant European presence beyond Germany (26% in Rest of Europe)
• Global footprint with representation across all major regions

Work Arrangement Diversity

• 35% of employees work part-time (maintained consistently from previous year)
• This represents significant flexibility in work arrangements and accommodation of different employee needs

Age Structure

• Average age: 42.1 years (decreased from 42.6 years previous year)
• Average seniority: 13.7 years (decreased from 14.2 years previous year)
• The slightly younger average age may indicate successful recruitment of younger employees

Training and Development Diversity

• 1,860 apprentices in training across around 30 different occupations and various combined degree courses
• Training programs offered worldwide, supporting diversity in career development opportunities
• Increase from 1,640 apprentices in previous year, showing expanded commitment to diverse talent development

Business Segment Diversity Workforce distributed across diverse business areas:

• Passenger Airlines: 64%
• MRO (Maintenance, Repair, Overhaul): 24%
• Additional Businesses and Group Functions: 8%
• Logistics: 4%

This distribution shows diversity in technical, operational, and service roles across the aviation value chain.

Commitment to Equal Opportunity The comprehensive approach to diversity includes:

• Equal opportunity initiatives
• Promotion of diversity as strategic priority
• Integration with broader human resources and corporate culture strategies
• Support for flexible career paths within partnership-based corporate culture

Adequate wages

S1-10 – Adequate wages

The Lufthansa Group and its companies strive to ensure that employees receive adequate remuneration. This applies to all employee groups regardless of location. The remuneration for the majority of employees is negotiated and set through collective agreements with labour union partners. The Lufthansa Group regularly reviews country-specific average market salaries and the economic and legal frameworks, such as inflation trends or statutory minimum wage requirements. This not only reflects the Lufthansa Group's commitment as a socially responsible employer but is also an essential prerequisite for positioning the Company as an attractive employer that recognises the contribution of its employees to its success.

Benchmark used

No specific living wage benchmark is disclosed. The company references:

• Collective agreements with labour union partners
• Country-specific average market salaries
• Economic and legal frameworks including inflation trends
• Statutory minimum wage requirements

Coverage and scope

The disclosure states that remuneration applies to "all employee groups regardless of location" and that "the majority of employees" have remuneration negotiated through collective agreements. No specific percentage of workforce coverage is provided.

Methodology

The Lufthansa Group "regularly reviews" country-specific market salaries and legal frameworks, but no specific frequency, methodology details, or living wage calculation approach are disclosed.

Value chain workers

Under S2-4, the Supplier Code of Conduct references ILO core labour standards and the complaint channel received two reports related to "withholding of adequate wages" in 2024, which could not be substantiated. However, no systematic living wage assessment for value chain workers is described.

Social Protection

Comprehensive Social Benefits Package The Lufthansa Group attaches great importance to offering its staff an attractive working environment with a wide range of social benefits as part of its comprehensive approach to employee welfare.

Pension System Management The Lufthansa Group actively manages its social protection obligations:

• Has largely switched over to a defined contribution pension system to limit further increases in liabilities
• Net pension obligations: EUR 2,566m (decreased from EUR 2,676m previous year)
• For largest remaining defined benefit pension plans, allocation of pension assets has been adjusted through introduction of liability driven investment (LDI) system
• LDI system aligns sensitivity of plan assets to interest rates more closely to pension obligations, permanently reducing volatility

Holiday and Leave Benefits Collective agreements secured enhanced holiday protection:

• Increased holiday pay across multiple employee groups
• Additional holiday bonus benefits for ground staff
• Further holiday bonus benefits included in wage agreements

Inflation Protection Inflation bonuses provided across all major employee groups as part of 2024 collective agreements:

• Ground staff inflation bonus
• Cabin crew inflation bonus
• Austrian Airlines staff inflation bonus
• Eurowings pilots and cabin crew inflation bonus
• Technical staff inflation bonus

These bonuses provide additional social protection against cost-of-living increases beyond base wage improvements.

Work-Life Balance Support

• 35% of employees work part-time, enabling work-life balance
• Flexible career paths supported within partnership-based corporate culture
• Support for diverse working arrangements accommodating different employee needs

Training and Development Security

• 1,860 apprentices receive comprehensive training with special benefit packages
• Extensive opportunities for ongoing development contributing to long-term employment security
• Apprentice remuneration adjustments ensuring adequate support during training periods

Long-term Employment Security

• Multi-year collective agreements (2-3 years typically) providing employment stability
• Planning certainty for both parties through longer-term agreements
• Reduced fluctuation rate to 6% (from 7%) indicating improved job security and satisfaction

Health and Safety Framework While specific details are limited in this section, the comprehensive social protection includes adherence to aviation industry safety standards and regulatory requirements for employee protection.

Special Support Programs

• Special packages for apprentices ensuring adequate support during training
• Support for disadvantaged people worldwide through help alliance, the Group's aid organisation

Social Partnership Approach Social protection is delivered through partnership-based relationships with trade unions, ensuring:

• Balance between company interests and employee welfare
• Transparent structures in employment relationships
• Conflict resolution mechanisms including mediation and arbitration for protection of employee rights

Training and Skills Development Metrics

Apprenticeship and Training Programs At year-end 2024, 1,860 apprentices were in training for around 30 occupations and various combined degree courses offered by the Lufthansa Group worldwide (previous year: 1,640). This represents a 13.4% increase in apprenticeship positions, demonstrating the Group's commitment to skills development.

Training Diversity and Coverage:

• Around 30 different occupations covered in apprenticeship programs
• Various combined degree courses offering academic and practical training
• Worldwide availability of training programs across Group locations
• Special packages for apprentices included in collective agreements

Professional Development Framework The Lufthansa Group offers its employees extensive opportunities for their ongoing development, contributing to:

• Employee satisfaction
• Safeguarding jobs
• Long-term talent retention
• Career advancement

Finance Academy Initiative As part of the Finance Transformation Programme, the launch of the Finance Academy has helped to advance:

• Professional training courses
• Targeted talent development measures
• Modernisation of finance function capabilities

Skills Development Strategy The comprehensive approach to training and development supports:

• Flexible career paths within the organization
• Individual development opportunities as core corporate value
• Partnership-based approach to employee growth
• Continuous professional development aligned with business needs

Training Investment and Support

• Enhanced benefits for apprentices through collective agreements
• Special provisions ensuring adequate support during training periods
• Remuneration adjustments for apprentices (e.g., Austrian Airlines from January 2025)

Skills Development Impact

• Contributing to reduced fluctuation rate (6% vs 7% previous year)
• Supporting successful recruitment measures in operational areas
• Enabling workforce to adapt to changing business requirements
• Building capabilities for digital transformation and modernization initiatives

Training Areas and Focus While specific metrics by training area are not detailed, the programs cover:

• Technical and operational aviation skills
• Digital and IT capabilities
• Customer service and commercial skills
• Safety and regulatory compliance
• Leadership and management development

International Training Approach Training programs are offered worldwide, supporting:

• Global workforce development
• Consistent skill standards across regions
• Transfer of best practices
• Cultural diversity in learning approaches

Continuous Learning Culture The emphasis on ongoing development rather than one-time training indicates a culture of continuous learning that adapts to:

• Industry evolution
• Technology changes
• Regulatory requirements
• Customer service improvements

Health and safety metrics

Coverage of health and safety management system

100% of Lufthansa Group employees are covered by a corresponding management system. Based on a Group-wide guideline, all Lufthansa Group employees are covered by the health and safety management system. The globally applicable Lufthansa Group occupational safety guideline provides the central framework for safety and health at work.

Fatalities and work-related accidents

Fatality details: During the reporting year, an incident occurred on a SWISS flight in which two employees were hospitalised with injuries, one of which subsequently died in the hospital. In addition, one Lufthansa Group employee died on a business trip from the consequences of an illness.

Accident details: Across all companies, a total of 1,357 workplace accidents occurred that resulted in at least one calendar day of absence. This corresponds to a rate of 9.4 workplace accidents per 1 million working hours.

Days lost

Not disclosed.

Methodology notes

Data collection is from individual legal entities within the scope of non-financial reporting. Terminology has been clearly defined and rolled out across the Group. Low uncertainty exists due to variations in national health and safety laws and their interpretation. These figures relate to the end of the year (as of 31/12/2024).

Work-Life Balance Metrics

Part-Time Employment 35% of employees worked part-time in the reporting year (unchanged from previous year: 35%). This represents a significant portion of the workforce and demonstrates the Group's commitment to providing flexible work arrangements that support work-life balance.

Work-Life Balance Framework The Lufthansa Group pursues a comprehensive approach which ensures work-life balance as one of its key pillars alongside:

• Equal opportunity
• Promotion of diversity
• Professional training

This comprehensive approach supports the Company's goal of being an attractive employer while promoting and retaining talent on a long-term basis.

Flexible Career Paths The Company strives to achieve a partnership-based and transparent corporate culture that supports flexible career paths, enabling employees to balance professional development with personal needs.

Holiday and Leave Benefits Collective agreements secured in 2024 enhanced work-life balance through improved holiday provisions:

• Increased holiday pay across multiple employee groups
• Additional holiday bonus benefits for various staff categories
• Further holiday bonus benefits included in wage agreements

These improvements provide better financial support for time away from work and enhanced recreational opportunities.

Work Arrangement Diversity The maintenance of 35% part-time employment rate indicates:

• Consistent accommodation of different employee needs
• Stable policy supporting work-life balance
• Recognition that flexible arrangements contribute to employee satisfaction
• Successful integration of part-time workers across business operations

Employee Satisfaction Indicators Work-life balance measures appear to contribute to positive employment outcomes:

• Reduced fluctuation rate to 6% (from 7% previous year)
• Workforce growth of 5% indicating successful attraction and retention
• Increased apprenticeship positions (1,860 vs 1,640) suggesting attractive career development

Cultural Journey Programme The Cultural Journey programme aims to enhance corporate culture with values that support work-life balance:

• Respect for individual needs
• Individual development opportunities that accommodate personal circumstances
• Diversity in work arrangements and career paths

Long-term Stability Multi-year collective agreements (typically 2-3 years) provide:

• Planning certainty for employees to balance work and personal commitments
• Stable employment conditions supporting long-term life planning
• Predictable benefits that facilitate work-life balance decisions

Partnership-Based Approach The partnership-based corporate culture emphasizes:

• Transparent structures that support employee needs
• Efficient processes that respect employee time
• Individual development opportunities aligned with personal goals
• Balance between company interests and employee welfare

Compensation metrics

Pay gap

The Lufthansa Group is committed to ensuring comparable pay for comparable work and intends to keep emphasising this topic. The gender pay gap shown here represents the difference between the average total remuneration of female and male employees. It is calculated by deducting the gross hourly wage of female employees from the average gross hourly wage of male employees and dividing this figure by the average gross hourly wage of male employees.

The gender pay gap calculation is based on a comparison of total remuneration, accounting for all components such as fixed and variable payments and benefits. It is based on the overall comparison of all remuneration figures regardless of employee group, position, subsidiary or country. In the reporting year, the gender pay gap was 27% in the favour of male employees. This is an unadjusted figure, in line with the calculation requirements of ESRS S1-16, and therefore does not reflect structural differences.

The characteristics of large groups of employees in the Lufthansa Group mean that the figure is of minimal informative value. At the end of 2024, for example, out of around 34,200 flight assistants at the Lufthansa Group, including pursers, approximately 80% were female and 20% male. Among the 11,300 pilots at the Lufthansa Group, by contrast, 7% were female and 93% male. This shows that the above figure does not necessarily indicate a lack of fairness in remuneration.

Remuneration ratio

The annual total remuneration ratio expresses the ratio of the highest paid individual's annual total remuneration to the median annual total remuneration of all employees. To reach this figure, the annual total remuneration of the highest paid individual is divided by the median annual total remuneration for all employees (excluding the highest-paid individual). In the reporting year, the highest paid individual was the Chairman of the Executive Board of Deutsche Lufthansa AG. The annual total remuneration ratio at the Lufthansa Group in 2024 came to 1:86. All components of remuneration – fixed and variable payments as well as benefits received during the 2024 financial year – were included in the calculation.

Methodology

The gender pay gap represents the difference between the average total remuneration of female and male employees, calculated by deducting the gross hourly wage of female employees from the average gross hourly wage of male employees and dividing this figure by the average gross hourly wage of male employees. The calculation is based on a comparison of total remuneration, accounting for all components such as fixed and variable payments and benefits, regardless of employee group, position, subsidiary or country.

For the remuneration ratio, the annual total remuneration of the highest paid individual (the Chairman of the Executive Board) is divided by the median annual total remuneration for all employees (excluding the highest-paid individual). All components of remuneration – fixed and variable payments as well as benefits – are included.

Incidents, Complaints and Severe Human Rights Impacts

Conflict Resolution Framework The collective agreements concluded in 2024 include comprehensive frameworks for addressing incidents and complaints:

Established Conflict Resolution Mechanisms:

• Mediation processes built into collective agreements
• Arbitration procedures for formal dispute resolution
• These mechanisms form core aspects of collective bargaining agreements

Specific Examples of Conflict Resolution Systems:

Discover Airlines Agreement:

• Framework agreement includes "agreement on conflict resolution mechanisms such as mediation and arbitration"
• Agreement "cannot be terminated until 31 December 2027" providing long-term stability for dispute resolution
• Represents "first wage agreement" establishing comprehensive conflict resolution framework

Ongoing Negotiation Processes:

• UFO terminated applicable framework agreement as of end 2024
• Negotiations on working conditions for cabin crew likely from 2025 onwards
• Demonstrates ongoing dialogue mechanisms for addressing workplace concerns

Partnership-Based Approach to Incident Prevention: The Company strives to achieve a partnership-based and transparent corporate culture that:

• Supports open communication
• Provides transparent structures for raising concerns
• Enables flexible career paths reducing potential for workplace conflicts
• Promotes individual development opportunities

Systematic Approach to Employee Relations:

Employee Survey Mechanism:

• Company-wide "involve me!" employee survey helps identify strategic areas of action
• Provides systematic method for employees to raise concerns and provide feedback
• Results integrated within Group's HR strategy for addressing issues

Long-term Stability Measures:

• Multi-year collective agreements (typically 2-3 years) reducing potential for recurring conflicts
• Planning certainty for both parties minimizing disputes
• Longer-term agreements establishing stable frameworks for issue resolution

Balancing Interests: Social and collective bargaining policies aim to:

• "Strike a balance between the interests of the companies and employees" in every Group part
• Define "good working conditions and fair salary arrangements"
• Develop "sustainable relationships between collective bargaining partners"

Preventive Measures:

Cultural Journey Programme:

• Aims to enhance corporate culture with values including "respect" and "diversity"
• Promotes cooperation between Group companies reducing potential conflicts
• Addresses "changing requirements of society, workforce and shareholders"

Training and Development:

• Extensive opportunities for ongoing development reducing employment-related grievances
• 1,860 apprentices in comprehensive training programs with proper support structures
• Professional development contributing to employee satisfaction

Human Rights and Social Responsibility: While specific human rights incident metrics are not detailed, the Group demonstrates commitment through:

• Support for "disadvantaged people worldwide" through help alliance aid organisation
• "Equal opportunity and promotion of diversity" as organizational strength
• Comprehensive approach ensuring equal opportunity across all operations

Regulatory Compliance: Operations under "numerous national and European regulations" including:

• Consumer protection policies
• Employment law requirements
• Aviation industry standards
• Data protection regulations

The systematic approach to collective bargaining, conflict resolution, and employee engagement suggests a structured framework for preventing and addressing workplace incidents and complaints, though specific incident numbers or complaint resolution metrics are not provided in the available information.

Policies related to value chain workers

Deutsche Lufthansa has established several policies governing workers in the value chain, primarily focused on human rights, environmental protection, and responsible business conduct.

Policy Statement on the German Corporate Due Diligence in Supply Chains Act (LkSG)

Scope: Applies worldwide to all consolidated companies of the Lufthansa Group unless they are legally required to publish their own statement. Covers all direct suppliers and, through ad hoc analysis, indirect suppliers when substantiated information is obtained.

Governance: Approved annually by the Executive Board of Deutsche Lufthansa AG. A dedicated Human Rights Officer within the Human Resources and Infrastructure division reports directly to the responsible Executive Board member and the Group Executive Board. The Group Human Rights Steering Board serves as a steering committee capable of making recommendations on risk management. The Corporate Audit function regularly verifies that implementation is appropriate and effective.

Key content/principles: Outlines the Company's human rights strategy and fulfillment of due diligence requirements. Addresses material impacts including human and labour rights in the value chain, training and development opportunities in the value chain, and social dialogue in the value chain. Expects employees and suppliers to respect human and environmental rights, prevent related impacts and risks, and avoid, mitigate or eliminate violations. The policy is updated and published annually in line with the impact assessment conducted during the reporting year.

Public availability: Publicly available on the Lufthansa Group website.

International frameworks: Based on:

• United Nations' Universal Declaration of Human Rights
• International Covenant on Civil and Political Rights (ICCPR)
• International Covenant on Economic, Social and Cultural Rights (ICESCR)
• The four core work standards of the International Labor Organization (ILO)
• UN Guiding Principles on Business and Human Rights
• The ten principles of the UN Global Compact
• OECD Guidelines for Multinational Enterprises
• IATA Resolution against Human Trafficking
• Environmental agreements such as the Minamata Convention on Mercury, the Stockholm Convention on Persistent Organic Pollutants and the Basel Convention on the Transboundary Movement of Hazardous Wastes and their Disposal

Monitoring: The Lufthansa Group reviews the effectiveness of its prevention and remedial measures on an ad hoc basis – at least annually – and makes adjustments as necessary. This process includes evaluating feedback from affected parties, gathering input from target groups and conducting audits. An active exchange is sought with internal stakeholder groups such as employee initiatives and staff representative bodies, as well as with external stakeholders.

Group Procurement Policy

Scope: Mandatory requirement for all purchasing units of Group companies and their employees involved in the procurement process. Applies to all direct suppliers.

Governance: Centrally approved by the Group Executive Board. Accessible to all employees on the intranet.

Key content/principles: Obligates suppliers to assume social and environmental responsibility. Includes adherence to the ten principles of the UN Global Compact, the four core labour standards of the International Labour Organization, and contractual requirements under the German Corporate Due Diligence in Supply Chains Act (LkSG). By including obligations in contracts with suppliers, the Lufthansa Group endeavours to ensure responsible practices by its direct suppliers in order to meet its own standards for corporate responsibility and prevent negative impacts.

International frameworks: References UN Global Compact principles, ILO core labour standards, and German LkSG requirements.

Monitoring: Implemented through procurement processes. Human rights and environmental requirements are included in tender specifications and evaluation matrices for supplier selection.

Supplier Code of Conduct

Scope: Applies to all suppliers of the Lufthansa Group, their employees and subcontractors. Supplier contracts refer to the Code of Conduct.

Governance: Approved by the Senior Vice President Procurement Group.

Key content/principles: Sets minimum standards for suppliers across three core sustainability areas: environmental protection, social aspects, and responsible corporate governance. Focus is on respecting human rights, complying with labour and health standards, protecting the environment and conducting business with integrity. Expects suppliers to comply with applicable laws and regulations of the countries in which they procure, manufacture, offer or supply products or services. The Lufthansa Group does not tolerate any unethical business conduct such as corruption, bribery, forced labour, child labour or violations of environmental, labour and social standards, and expressly prohibits such practices.

Public availability: Publicly available on the Lufthansa Group website.

International frameworks: Takes into account:

• United Nations' Universal Declaration of Human Rights
• International Covenant on Civil and Political Rights (ICCPR)
• International Covenant on Economic, Social and Cultural Rights
• The four core labour standards of the International Labor Organization (ILO)
• UN Guiding Principles on Business and Human Rights
• The ten principles of the UN Global Compact
• OECD Guidelines for Multinational Enterprises
• International Air Transport Association (IATA) Resolution against Trafficking in Persons
• Environmental agreements such as the Minamata Convention on Mercury, the Stockholm Convention on Persistent Organic Pollutants and the Basel Convention on the Transboundary Movement of Hazardous Wastes

Monitoring: Suppliers are subjected to country, industry and media-based screening. Annual and ad hoc human rights and environmental risk analyses are conducted for all existing suppliers. Suppliers with potential negative impacts are weighted according to their priority for action. The Group Procurement Team manages risk regarding suppliers, supported by contact persons from specialist departments.

Code of Conduct

Scope: Binding for all employees of the Lufthansa Group worldwide, regardless of their role or level. Also defines expectations of the Company's business partners, including suppliers.

Governance: Updated by the Chief Compliance Officer and approved by the Group Executive Board of Deutsche Lufthansa AG.

Key content/principles: Supports employees in making decisions that align with the Company's principles and values. Covers topics including respect for human rights, occupational safety and health, fair competition, anti-corruption measures, handling conflicts of interest, digitalisation and data protection, and external communication. The Lufthansa Group treats employees and other stakeholders with respect and rejects all forms of discrimination, harassment and violence. Conduct is based on valuing and including people regardless of their national or ethnic background, gender, religion, beliefs, disability, age or sexual identity.

Public availability: Available on the Lufthansa Group website.

Monitoring: Violations of the Code of Conduct can lead to severe penalties for the Company and for individual employees. The Corporate Compliance Office is responsible for editorial coordination, while the Executive Board is responsible for implementation.

Taking action on material impacts on value chain workers

Sustainability criteria integrated in supplier selection and procurement processes

Scope: Upstream value chain (suppliers)

Description: The Lufthansa Group has adapted its procurement processes so that sustainability criteria play a key role in supplier selection. Human rights and environmental requirements are included in the specification during the tender process and are to be included in the evaluation matrix for supplier selection.

Before contract conclusion: Suppliers are generally assessed for compliance with human rights, labour and environmental standards and integrity. A supplier review process is conducted, with suppliers informed about Lufthansa Group's expectations through tender documents referencing the Supplier Code of Conduct.

Key elements:

• Human rights and environmental aspects included in procurement process
• Sustainability criteria in tender specifications and evaluation matrices
• Pre-contract supplier assessments for human rights, labour, environmental standards and integrity

Link to policy: Supplier Code of Conduct

Supplier investigation, monitoring and assessment programme (2024)

Scope: Upstream value chain (suppliers)

Time horizon: 2024 (ongoing)

Actions carried out, planned or implemented in 2024:

• Over 200 internal and external investigations of critical suppliers and external incidents concluded
• More than 50 further investigations initiated
• Over 25 self-assessment questionnaires collected from business partners
• 10 cases where further information was requested in the form of individual statements and direct correspondence with suppliers
• Supplier training programme conducted
• 10 cases where additional documents were requested from suppliers (7 already reviewed), including:
  • Certificates
  • Codes of conduct
  • Anti-discrimination and human rights procedures
  • Rules of procedure for supplier grievance mechanisms
• 7 supplier contracts reviewed, including terms and conditions, and revised or supplemented to include ESG criteria where necessary

Resources (non-financial): Central expert team from Group Procurement monitors implementation of measures in collaboration with responsible purchasers. Weekly exchange between Human Rights Department experts and Group Procurement to discuss complaints, material negative impacts, possible measures and further action.

Expected outcomes: Continuously improve the Lufthansa Group's supplier base, particularly with regard to human rights aspects.

Risk-based remedial and preventive measures for suppliers

Scope: Upstream value chain (suppliers)

Description: When the Lufthansa Group detects an actual or imminent violation of human rights or environmental obligations, it introduces appropriate remedial and preventive measures. Measures are selected according to a defined logic based on risk categories.

Potential measures include:

• Developing and implementing a plan to eliminate or minimise violations together with the responsible company
• Awareness training
• Statements
• Contract reviews with possible adjustments
• Temporary suspension of business relationship (to reduce risk)
• Termination of business relationship (as last resort)

Monitoring: The Lufthansa Group monitors the implementation of remedial measures and evaluates results, which may involve correspondence with whistleblowers.

Resources (non-financial): Central team of experts from Procurement handles measures for suppliers, in consultation with responsible purchasers.

Audits of human rights and environmental due diligence

Scope: Upstream value chain (direct and indirect suppliers)

Description: Audits are conducted to verify whether human rights and environmental due diligence obligations are being upheld and whether the Lufthansa Group's risk management system is adequate.

Conducted by:

• Corporate Audit (primarily)
• External auditors (for direct suppliers and, where necessary, indirect suppliers in individual cases)

Outcomes: Audit findings contribute to the sustainability-focused design of procurement processes and purchasing strategies. Measures are tracked on a continuous basis electronically. Audit findings (positive or negative) contribute to improving or deteriorating risk assessments.

Freedom of association monitoring

Scope: Upstream value chain

Description: Freedom of association for workers in the value chain has been deemed particularly relevant. As part of the risk analysis, freedom of association is continuously monitored and evaluated.

Note: Global framework agreements are yet to be concluded with international trade union federations in this context.

Governance structure for human rights risk management

Resources (non-financial):

• Human Rights Officer: Role established within Human Rights and Infrastructure, reporting directly to Executive Board member. Exercised by Vice President of Labor Relations Ground. Reports to Group Executive Board on regular and ad hoc basis.

• Group Human Rights Steering Board: Established as governance body to provide recommendations and guide decisions on risk management. Chaired by Human Rights Officer, comprises heads of Sustainability, Compliance, Audit, Procurement and Occupational Safety departments.

• Corporate Audit: Deployed to support the Human Rights Officer and conduct implementation-level audits. Regularly verifies that implementation is appropriate and effective.

Targets related to supplier risk management

Time horizon: Ongoing

Specified targets include:

• Implementation of risk assessment for existing suppliers using previously implemented risk assessment system
• Continuously updating supplier questionnaires based on regulatory requirements and insights from risk assessments
• Continuously updating relevant clauses in contract templates
• Ongoing efforts to improve and further develop sustainability performance among suppliers
• If action deemed necessary, specified measures to be agreed upon with suppliers

Link to targets: See S2-5 disclosure requirement

Media monitoring for high-risk suppliers

Scope: Upstream value chain (high-risk suppliers)

Description: Media monitoring is conducted for high-risk suppliers. Violations identified through media observation, grievance mechanisms or other findings contribute to deterioration in risk assessment and assist with evaluating effectiveness of measures taken.

Targets related to value chain workers

Approach to Target Setting

Group Procurement at Lufthansa Group is committed to accounting for material impacts, risks and opportunities related to workers in the value chain when developing relevant procurement processes. The purpose behind this is to identify potential human rights, environment-related and compliance risks and violations in the supply chain in order to prevent, minimise or eliminate these risks and violations through appropriate measures.

Targets are defined on the basis of results from previous risk assessments and complaints received through the complaints procedure. Depending on the case, insights gained from this process feed into the continuous development of the risk management system.

Measures are to be agreed upon with suppliers.

No Specific Quantified Targets Disclosed

No specific quantified targets with target values, target years, baseline years, or baseline values are disclosed in the provided excerpts for ESRS S2-5 relating to workers in the value chain.

Policies Related to Consumers and End-Users

Customer-Centric Strategy Customers are at the heart of the Group strategy. The Lufthansa Group aims to offer travel products with the highest quality standards as well as consistent solutions along the entire travel chain. An even greater focus on the customer is a core element of the Group strategy.

Premium Positioning and Quality Standards The Lufthansa Group strives to:

• Consistently achieve its premium positioning
• Expand its product range in line with industry trends and customer feedback
• Continue refining its loyalty programme
• Fulfill its promise as a premium provider at every point of contact throughout the travel chain
• Simplify the travel experience while maintaining high standards

Customer Service and Experience Policies

Service Quality Framework:

• Safe and reliable flight operations are a core focus at all times
• Passengers receive a holistic service featuring:
  • Comfortable seating and lounges
  • Attentive staff
  • Innovative digital services
• Consistent solutions along the entire travel chain

Digital Customer Services:

• Use of chatbots for customer interaction
• Option to pre-order in-flight meals
• Automated processes to satisfy customer requirements in case of flight irregularities
• New digital customer services on the ground including information on walking times at airports
• Selected locations feature new check-in areas for First Class and HON-Circle customers

Customer Communication and Segmentation:

• Customer communication activities adjusted in line with various customer segments
• Tailored to individual requirements of different customer groups
• Focus on aspects highly relevant for customers that influence repeat purchase decisions and willingness to pay

Product and Service Development Policies

Innovation and Personalization:

• Providing wider choice of individually selectable product components
• Travel experience that caters to passengers' individual requirements
• On board and on the ground services, particularly in the premium segment
• New cabin layouts and seating generations (Lufthansa Allegris, SWISS Senses)

Loyalty and Recognition Programs:

• Expansion of existing customer loyalty concept
• Greater individual appreciation for every passenger
• Continuous expansion of Lufthansa Group Travel ID
• Recognition of customers at every point of contact, regardless of airline
• Matching services and offerings with personal needs of passengers

Sustainability Integration:

• Green Fares offering including carbon offsets rolled out to all long-haul flights
• Sustainable aviation fuel (SAF) offerings for customers
• Tailored services enabling customers to reduce carbon emissions from flights
• High-quality climate protection projects for offsetting

Consumer Protection and Accessibility

Service Accessibility:

• Digital customer portal enabling customers to:
  • Access all relevant journey information
  • Resolve issues such as rebookings or refunds
  • Purchase additional products quickly and intuitively
• New, interactive self-service options
• Automated customer services, particularly for compensation claims

Quality Assurance:

• Net Promoter Score (NPS) as indicator of customer satisfaction
• Measures willingness of customers to recommend Lufthansa Group Airlines services
• Focus on customer satisfaction together with operational areas and other interfaces

Regulatory Compliance: The Group operates under more stringent European and national consumer protection policies which may lead to:

• Efforts to introduce insolvency protection for flights
• Automating refund and compensation payments
• Enhanced customer rights and protection measures

These policies demonstrate the Lufthansa Group's commitment to putting customers at the center of its strategy while maintaining high service standards, innovating in digital services, and integrating sustainability into customer offerings.

Processes for Engaging with Consumers and End-Users

Customer Feedback and Satisfaction Measurement

Net Promoter Score (NPS) System:

• Net Promoter Score (NPS) serves as primary indicator of customer satisfaction
• Measures willingness of customers to recommend the services of Lufthansa Group Airlines
• Used to assess customer satisfaction together with operational areas and other interfaces
• Provides systematic measurement of customer engagement and loyalty

Digital Customer Engagement Platforms

Comprehensive Digital Portal:

• Digital customer portal enables customers to:
  • Access all relevant information relating to their journey
  • Resolve issues such as rebookings or refunds
  • Purchase additional products quickly and intuitively
• Features new, interactive self-service options
• Provides quick and intuitive problem resolution capabilities

Multi-Channel Communication:

• Use of chatbots for customer interaction and support
• Automated customer services expansion, particularly for compensation claims
• Digital service channels for various customer service needs

Personalized Customer Recognition

Lufthansa Group Travel ID:

• Continuous expansion of the Travel ID system
• Recognises customers at every point of contact, regardless of which airline they're flying
• Enables matching services and offerings with personal needs of passengers
• Provides seamless experience across all Lufthansa Group Airlines

Customer Segmentation and Tailored Communication:

• Customer communication activities adjusted in line with various customer segments
• Tailored to individual requirements of different customer groups
• Recognition that different customers have different needs and preferences

Product Development Engagement

Customer Feedback Integration:

• Product range expansion in line with industry trends and customer feedback
• Continuous refinement of loyalty programme based on customer input
• Focus on aspects highly relevant for customers that influence:
  • Repeat purchase decisions
  • Willingness to pay
  • Overall customer satisfaction

Individual Service Customization:

• Wider choice of individually selectable product components
• Travel experience that caters to passengers' individual requirements
• Premium segment focus on personalized service delivery
• On board and on the ground service customization

Customer Service Innovation

Enhanced Ground Services:

• New check-in areas for First Class and HON-Circle customers at selected locations
• Information on walking times at airports through digital services
• Strengthening the hospitality profile of Lufthansa Group Passenger Airlines

Loyalty Programme Evolution:

• Expansion beyond somewhat transactional concept of customer loyalty
• Greater individual appreciation for every passenger
• Personal interaction and recognition approaches
• Demonstration of appreciation rather than purely transactional relationships

Operational Excellence for Customer Engagement

Service Quality Focus:

• Safe and reliable flight operations as foundation for customer trust
• Holistic service approach featuring comprehensive customer experience
• Focus on premium positioning and consistent service delivery

Digital Innovation:

• World's best airline app (rated by World Aviation Festival, October 2024)
• App enables comprehensive self-service options
• Quick and easy issue resolution through interactive features
• Access to all relevant information and services

Continuous Improvement Process:

• Ongoing development of customer service capabilities
• Integration of customer feedback into service enhancement
• Partnership-based approach to customer relationship management
• Focus on simplifying the travel experience while maintaining quality standards

Processes to Remediate Negative Impacts and Channels for Consumers and End-Users

Digital Self-Service Remediation

Comprehensive Digital Portal: The digital customer portal provides primary remediation channels enabling customers to:

• Resolve issues such as rebookings or refunds quickly and intuitively
• Access new, interactive self-service options for problem resolution
• Handle various service issues through automated processes
• Purchase additional products and services as compensation

Automated Compensation Systems:

• Automated processes specifically designed to satisfy customer requirements in case of flight irregularities
• Automated customer services expansion, particularly for justified compensation claims
• Digital channels prioritize quick and intuitive problem resolution

Multiple Communication Channels

Interactive Customer Support:

• Use of chatbots for customer interaction and immediate assistance
• Digital service channels providing various remediation options
• Multi-channel approach ensuring customers can reach support through preferred methods

App-Based Solutions:

• World's best airline app (World Aviation Festival rating, October 2024) provides:
  • All relevant information relating to customer journey
  • Quick and easy issue resolution capabilities
  • Interactive self-service options for immediate problem solving
  • Comprehensive access to remediation services

Personalized Remediation Approach

Travel ID Integration:

• Lufthansa Group Travel ID recognises customers at every point of contact
• Enables matching services and offerings with personal needs during remediation
• Provides consistent remediation experience regardless of which airline customer is flying
• Supports individual appreciation during problem resolution

Segmented Customer Service:

• Customer communication activities adjusted for different customer segments during remediation
• Tailored approach to individual requirements in problem resolution
• Recognition that different customers may need different remediation approaches

Premium Service Recovery

Enhanced Service for Premium Customers:

• New check-in areas for First Class and HON-Circle customers providing dedicated remediation support
• Premium positioning maintained even during service recovery situations
• Holistic service approach extends to problem resolution

Operational Excellence in Remediation

Proactive Communication:

• Information on walking times at airports helps prevent customer issues
• Digital customer services on the ground provide immediate support
• Pre-emptive service to minimize negative impacts

Quality Assurance:

• Net Promoter Score (NPS) measures effectiveness of remediation efforts
• Tracks willingness of customers to recommend services despite experiencing issues
• Customer satisfaction measurement includes remediation effectiveness

Regulatory Compliance Framework

Consumer Protection Alignment: Operations under more stringent European and national consumer protection policies including:

• Automating refund and compensation payments as required by regulations
• Enhanced customer rights protection during remediation
• Compliance with consumer protection requirements

Systematic Improvement Process

Continuous Enhancement:

• Focus on aspects highly relevant for customers that influence:
  • Future purchase decisions after negative experiences
  • Willingness to pay despite previous issues
  • Overall customer retention after problems

Product Development Integration:

• Customer feedback from remediation processes integrated into:
  • Product range expansion
  • Service quality improvements
  • Industry trends response
  • Loyalty programme refinement

Service Recovery Strategy:

• Simplifying the travel experience includes making remediation processes simpler
• Premium provider promise maintained during service recovery
• Focus on consistent solutions throughout entire remediation process

Taking Action on Material Impacts on Consumers and End-Users

Comprehensive Customer Experience Enhancement Strategy

The Lufthansa Group has implemented extensive measures to address material impacts on consumers and end-users, managing risks and pursuing opportunities through systematic customer-focused initiatives:

Product and Service Innovation Actions

Premium Service Delivery:

• Lufthansa Allegris and SWISS Senses product generation seating implementation offering new travel experience in every class on long-haul routes
• Seven A350 aircraft already in service with new Allegris interior by end of reporting year
• Austrian Airlines Boeing 787 Dreamliner introduction with new cabin layout designed to expand high-quality service offerings

Digital Service Enhancement:

• World's best airline app development (World Aviation Festival award, October 2024)
• Free Wi-Fi portal "FlyNet" providing access to free magazines and podcasts
• Digital service channels expansion and automated customer services particularly for compensation claims
• Interactive self-service options enabling quick and intuitive problem resolution

Sustainability Integration Actions

Environmental Service Options:

• Green Fares introduction for European flights including carbon offsets in pricing
• Roll-out to all long-haul flights of Green Fares offering
• Sustainable aviation fuel (SAF) offerings enabling customers to reduce carbon emissions
• High-quality climate protection projects for carbon offsetting
• Tailored services allowing customers to reduce carbon emissions from their flights

Fleet Modernisation for Customer Benefit:

• Fleet renewal with latest-generation aircraft providing:
  • Up to 30% lower fuel consumption benefiting environmental impact
  • Improved comfort and reduced environmental footprint
  • Enhanced reliability and reduced operational irregularities
• 242 aircraft on order (2025-2032) ensuring continued service improvements

Customer Service Excellence Actions

Personalized Service Development:

• Lufthansa Group Travel ID expansion providing customer recognition at every point of contact
• Individual appreciation for every passenger moving beyond transactional loyalty concepts
• Matching services and offerings with personal needs of passengers
• Customer segmentation enabling tailored communication to individual requirements

Ground Service Improvements:

• New check-in areas for First Class and HON-Circle customers at selected locations
• Information on walking times at airports through digital services
• Strengthened hospitality profile of Lufthansa Group Passenger Airlines

Operational Excellence Actions

Safety and Reliability Focus:

• Safe and reliable flight operations maintained as core focus at all times
• Holistic service approach featuring comfortable seating, attentive staff, and innovative digital services
• Operational stability and reliability firmly established in company DNA

Service Recovery Capabilities:

• Automated processes for customer requirements during flight irregularities
• Digital customer portal enabling customers to resolve rebookings, refunds, and purchase additional products
• Comprehensive self-service options for quick issue resolution

Risk Management and Opportunity Pursuit

Market Positioning Actions:

• Premium positioning maintenance while expanding product range based on industry trends and customer feedback
• Loyalty programme refinement to enhance customer retention
• Multi-hub strategy providing customers with extensive connectivity options

Competitive Response:

• Response to more stringent consumer protection policies through:
  • Automated refund and compensation payments
  • Enhanced customer rights compliance
  • Proactive service improvements

Effectiveness Measurement and Improvement

Performance Monitoring:

• Net Promoter Score (NPS) as primary customer satisfaction indicator
• Measurement of willingness to recommend services
• Customer satisfaction measurement integrated with operational performance

Continuous Enhancement:

• Focus on aspects highly relevant for customers influencing:
  • Repeat purchase decisions
  • Willingness to pay premium
  • Overall customer satisfaction and loyalty
• Customer feedback integration into product development and service improvement

Strategic Integration:

• Customer-centric approach integrated into overall Group strategy
• Value creation for both Lufthansa Group and customers through service excellence
• Premium provider promise maintained at every point of contact throughout travel chain

Innovation and Future Development:

• Chatbot technology and digital interaction improvements
• Pre-order meal options and enhanced in-flight services
• Simplification of travel experience while maintaining service quality
• Consistent solutions along entire travel chain development

Targets related to consumers

In the reporting year, the Lufthansa Group did not set any specific targets regarding its material impacts, risks and opportunities. In addition, no formal processes have been established for setting targets in relation to material impacts, risks and opportunities.

While the Lufthansa Group has not set measurable targets in this specific area, the effectiveness of existing policies and measures, as outlined in the respective descriptions of individual regulations, is regularly reviewed.

Business Conduct Policies and Corporate Culture

Corporate Culture Transformation The Lufthansa Group is continuing to pursue transformation with its Cultural Journey programme. The Company's corporate culture remains of key significance, with the commitment and well-being of the workforce being main priorities alongside financial success.

Core Corporate Values: The Cultural Journey programme brings together values such as:

• Diversity - promoted as organizational strength
• Respect - for individuals and stakeholders
• Individual development opportunities - supporting employee growth
• Partnership-based approach - in all stakeholder relationships
• Transparency - in structures and communications

Corporate Culture Development: The development of the Lufthansa Group's corporate culture is driven by a Group-wide initiative to:

• Promote cooperation between all Group companies and business segments
• Meet changing requirements of society, workforce and shareholders
• Address evolving customer and stakeholder expectations
• Foster flexible and enterprise-based mentality

Business Conduct Framework

Partnership-Based Business Approach: The Company strives to achieve a partnership-based and transparent corporate culture that:

• Supports stakeholder relationships
• Enables flexible approaches to business challenges
• Promotes efficient processes and decision-making
• Maintains transparent structures in all operations

Stakeholder Responsibility: Responsibility is the foundation of business activities in the Lufthansa Group. The Group aspires to lead the aviation sector with high standards in:

• Environmental commitment
• Social responsibility
• Fair treatment of employees and partners in the value chain
• Continuous expansion of sustainability commitments

Compliance and Governance

Regulatory Compliance: The Lufthansa Group operates under numerous national and European regulations and maintains compliance with:

• Consumer protection policies
• Data protection regulations
• Aviation security requirements
• Environmental regulations
• Employment and labor standards

Risk Management Integration: The Group's business conduct is supported by integrated risk management including:

• Structured risk management minimizing business risks
• Rule-based processes for operational decisions
• Early identification systems for potential issues
• Compliance monitoring and reporting systems

Social Partnership Approach

Collective Bargaining Philosophy: Within the scope of social and collective bargaining policies, the Lufthansa Group aims to:

• Define good working conditions and fair arrangements
• Strike balance between company and employee interests across all Group parts
• Develop sustainable relationships with collective bargaining partners
• Establish longer-term agreements providing planning certainty

Conflict Resolution: Business conduct includes comprehensive conflict resolution mechanisms such as:

• Mediation processes
• Arbitration procedures
• Transparent grievance procedures
• Partnership-based problem solving

Innovation and Excellence Culture

Continuous Improvement: The corporate culture emphasizes:

• Operational and commercial excellence
• Customer centricity as core business principle
• Innovation and digitalisation as strategic priorities
• Exceptional people as competitive advantage
• Value creation through sustainable business practices

Quality Standards:

• Premium positioning maintained through high conduct standards
• Safe and reliable operations as fundamental business principle
• Highest quality standards in products and services
• Consistent solutions along entire value chain

Sustainability Integration

Environmental Responsibility:

• Sustainability aspects included in product and service design
• Environmental commitment continuously expanded
• High standards in environmental performance
• Integration of sustainability into business decision-making

Social Responsibility:

• Equal opportunity and diversity promotion as organizational strength
• Support for disadvantaged people worldwide through help alliance
• Comprehensive approach to social responsibility
• Individual development opportunities for all stakeholders

Management of Relationships with Suppliers

Strategic Supplier Partnerships The Lufthansa Group manages extensive supplier relationships across its global operations, with particular focus on key operational partners and system suppliers.

Critical Supplier Dependencies:

Aircraft and Engine Suppliers:

• Ongoing delays in delivery of new aircraft creating capacity bottlenecks requiring supplier management
• Average of around 30 aircraft unavailable due to PW1100G engine inspection requirements from Pratt & Whitney
• Successfully negotiated with Pratt & Whitney to significantly reduce financial risks involved
• 64 Lufthansa Group aircraft and 136 engines affected requiring coordinated supplier response

Supplier Performance Impact:

• Strikes by employees at system partners had negative impact in first quarter 2024
• Supplier operational challenges contributing to overall business performance
• Need for alternative capacity arrangements (wet leases) due to supplier constraints

Supply Chain Risk Management

Mitigation Strategies: To address supplier-related risks, the Group implements:

• Acquiring additional replacement engines to reduce dependency on single suppliers
• Extending useful life of existing aircraft through enhanced supplier relationships
• Additional wet leases to compensate for supplier delivery delays
• Flexible fleet planning permitting adaptation to supplier performance variations

Procurement and Working Capital Management:

• Improvements to procurement processes as part of working capital optimization
• Optimising payment terms with suppliers to enhance cash flow management
• Strict receivables management including supplier payment coordination

Long-term Supplier Relationships

Aircraft Procurement Strategy:

• 242 aircraft on order from 2025-2032 representing major supplier commitments
• Options for 182 additional aircraft providing supplier relationship flexibility
• Multi-year procurement planning with major aerospace suppliers (Airbus, Boeing)
• Sale-and-lease-back transactions involving supplier finance partnerships

Engine Management Synergies: Group-wide engine management introduced to achieve supplier synergies:

• Joint use of replacement engines across Group airlines
• Joint purchase of MRO services for all Group airlines
• Increased negotiating power with engine suppliers and service providers
• Green time optimization through coordinated supplier relationships

Quality and Compliance Standards

Safety and Regulatory Compliance:

• Safety inspections coordinated with engine suppliers (PW1100G example)
• Regulatory compliance requirements applied to supplier relationships
• High standards maintained in supplier selection and management
• Aviation industry certification requirements for key suppliers

Service Quality Partners:

• System partners integrated into operational delivery
• Ground service suppliers supporting hub operations
• Technology partners for digital transformation initiatives
• MRO service providers supporting maintenance operations

Sustainable Supplier Practices

Sustainability Integration:

• Sustainable aviation fuel (SAF) suppliers as strategic partners
• Environmental commitment extended to supplier relationships
• Climate protection project partners for carbon offsetting services
• Supplier evaluation includes sustainability criteria

Innovation Partnerships:

• Research and technology partners for sustainable aviation development
• Digital innovation suppliers supporting transformation initiatives
• Training and development providers for workforce capabilities

Financial and Commercial Management

Payment and Terms Management:

• Working capital management includes supplier payment optimization
• Payment terms negotiation as part of supplier relationship management
• Supply chain financing arrangements with key partners
• Risk assessment of supplier financial stability

Value Creation Focus:

• Supplier relationships evaluated based on contribution to value creation
• Cost efficiency balanced with quality and reliability requirements
• Long-term partnership approach rather than purely transactional relationships
• Synergy exploitation through Group-wide supplier coordination

Operational Integration:

• Joint operational planning with critical suppliers
• Capacity coordination with lease and wet lease providers
• Maintenance scheduling coordinated with MRO suppliers
• Digital integration with key technology and service providers

Prevention and Detection of Corruption and Bribery

Compliance Management System The Audit Committee received regular reports on the compliance management system, indicating established processes for monitoring and managing compliance risks including corruption and bribery prevention.

Governance and Oversight

Audit Committee Supervision:

• Regular reports provided to Audit Committee on compliance management system
• Supervision of internal control systems including compliance monitoring
• Risk management oversight encompassing compliance and conduct risks
• Regular auditing of compliance processes and effectiveness

Corporate Governance Framework:

• Declaration of compliance with German Corporate Governance Code updated in September 2024
• No conflicts of interest disclosed in the 2024 financial year
• Transparent corporate culture promoted throughout organization

Risk Management Integration

Integrated Risk Management: The Group's approach to corruption and bribery prevention is integrated within structured risk management systems that:

• Minimize financial risks through rule-based processes
• Provide early identification of potential compliance issues
• Include regular monitoring and reporting mechanisms
• Apply systematic risk assessment across business operations

Partnership-Based Business Conduct: Partnership-based and transparent corporate culture supports prevention by:

• Promoting transparent structures in all business relationships
• Establishing clear processes for business decisions
• Maintaining high standards in business conduct
• Fair treatment of all stakeholders including suppliers and partners

Regulatory Compliance Framework

Regulatory Adherence: The Lufthansa Group operates under numerous national and European regulations requiring:

• Compliance with anti-corruption laws across multiple jurisdictions
• Consumer protection compliance including transparent business practices
• Data protection and privacy compliance
• Aviation industry specific regulatory requirements

International Standards:

• Operations across multiple countries requiring compliance with various anti-corruption frameworks
• Investment grade ratings from rating agencies indicating strong governance practices
• ESG rating participation (MSCI, Sustainalytics, CDP, ecovadis) including governance assessments

Organizational Culture and Training

Corporate Values: The Cultural Journey programme promotes values that support integrity:

• Transparency in all business operations
• Respect for stakeholders and business partners
• Partnership-based approach to business relationships
• Individual responsibility and ethical conduct

Employee Standards:

• Transparent structures in employment and business relationships
• Efficient processes reducing opportunities for inappropriate conduct
• Professional training including compliance and ethical conduct
• Partnership-based corporate culture promoting ethical behavior

Business Relationship Management

Supplier and Partner Management:

• Fair treatment of partners in the value chain as stated business principle
• High standards maintained in supplier and partner relationships
• Transparent business processes in procurement and contracting
• Rule-based processes for supplier selection and management

Stakeholder Engagement:

• Balance between company interests and stakeholder welfare in all relationships
• Sustainable relationships with business partners and suppliers
• Conflict resolution mechanisms including mediation and arbitration
• Regular dialogue with stakeholders on business conduct matters

Monitoring and Reporting

Regular Assessment:

• Regular reports to Audit Committee on compliance system effectiveness
• Internal auditing systems monitoring compliance with policies and procedures
• Risk management reporting including compliance risk assessment
• Performance measurement of compliance program effectiveness

External Validation:

• External auditor engagement for assurance on control systems
• Rating agency assessment of governance practices
• Regulatory compliance verification across multiple jurisdictions
• Industry benchmarking of compliance and governance practices

Incidents of corruption or bribery

Confirmed incidents and convictions

In 2024, there were zero convictions and EUR 0 in fines imposed on the Lufthansa Group for violations of anti-corruption or anti-bribery regulations.

The Lufthansa Group does not tolerate any violations of its anti-corruption and anti-bribery regulations. Should an investigation confirm a violation of applicable anti-corruption or anti-bribery regulations, the Lufthansa Group will take appropriate measures, taking into account the individual circumstances of each case. This may include disciplinary measures, claims for damages, increased training and awareness-raising activities, extraordinary internal audits, improvements to the standards concerned and processes to prevent future violations.

Investigation and speak-up mechanisms

The Lufthansa Group maintains various whistleblower channels to investigate allegations or incidents of corruption and bribery:

• All employees can contact their direct supervisors, the compliance managers in their Group company, or the Corporate Compliance Office
• An electronic whistleblower system for anonymous reporting
• An external ombudsperson, accessible to internal and external whistleblowers

The Business Keeper Management System (BKMS) allows whistleblowers to submit reports in writing at any time, with the option to remain anonymous. The ombudsperson is an independent lawyer not employed by the Lufthansa Group, and reports can be submitted by phone, in writing or in person.

Investigations of potential compliance violations, including corruption and bribery allegations, are conducted by the Corporate Compliance Office and the Intelligence & Investigations Team of Corporate Security. Depending on the severity of the allegations, investigations are reported either to the Group Compliance Committee or the responsible Central Compliance Committee. These committees are independent of the management chain involved in the matter.

The Corporate Compliance Office reports at least quarterly to the Group Compliance Committee summarizing all compliance-relevant allegations and incidents, including those of corruption and bribery, as well as the Lufthansa Group's relevant compliance investigations. Twice a year, the Corporate Compliance Office reports relevant incidents, allegations and investigations to the Executive Board and the Audit Committee of the Supervisory Board, and once a year to the Supervisory Board of the Lufthansa Group.

Protection of whistleblowers

The Lufthansa Group follows a zero-tolerance policy regarding retaliation against whistleblowers and protects those reporting concerns from any disadvantage arising from their complaints. Every complaints procedure is conducted confidentially and no one outside the procedure is informed of the whistleblower's identity, except where legally permitted under the German Whistleblower Protection Act. Employees are protected against disadvantages, disciplinary measures and discrimination because of a complaint. Retaliation against whistleblowers is not tolerated and such measures are investigated if reported through designated complaint channels.

Political influence and lobbying activities

Political engagement approach

The Lufthansa Group maintains representation for political influence and lobbying activities through designated representatives across its main entities. As of 2024, the Lufthansa Group had 79 named representatives engaged in political influence or lobbying activities across Deutsche Lufthansa AG, Lufthansa Cargo AG, Lufthansa Technik AG, Eurowings, Austrian Airlines, and Brussels Airlines.

The Lufthansa Group participates in public debate together with other European airlines, airports and industry associations, and campaigns actively for competition-neutral regulations in areas such as climate protection and environmental policy. The Company seeks to ensure and maintain various supplier requirements and to secure supply chains through engagement with policymakers.

Ethical standards and guidelines

The Lufthansa Group's Code of Conduct addresses anti-corruption, handling of conflicts of interest, fair competition, foreign trade regulations, anti-money laundering, insider information and prohibition of insider trading. The Group Compliance Guideline regulates the structure of the Lufthansa Group's Compliance Management System. The Integrity Compliance Guideline contains requirements for the prevention of corruption and bribery, including conflicts of interest, with clear rules for invitations and gifts, particularly in relation to public officials.

The Lufthansa Group is committed to comprehensive protection of whistleblowers within the framework of the established whistleblower system. The Code of Conduct and Group Compliance Guideline each contain provisions on preventing retaliation.

Political contributions

The Lufthansa Group reported financial political contributions and political benefits in kind for 2024:

No estimation was necessary for collecting the data.

Former public administration employees

The following employees in administrative, management and supervisory bodies of the Lufthansa Group held a comparable position in public administration, including regulatory authorities, in the two years before their appointment during the current reporting period:

• Tom Benedict
• Alexander Holzrichter
• Anna Maaßen

EU Transparency Register

The Lufthansa Group is registered in the following transparency registers:

European Union:

• Lufthansa Group, EU Transparency Register 0714344663-32
• Brussels Airlines, EU Transparency Register 755555322381-50

Germany:

• Deutsche Lufthansa AG, Lobby Register of the German Bundestag, Register number R001474
• Eurowings GmbH, Lobby Register of the German Bundestag, Register number R001213
• Lufthansa Cargo AG, Lobby Register of the German Bundestag, Register number R000854
• Lufthansa Technik AG, Lobby Register of the German Bundestag, Register number R003164

Austria:

• Austrian Airlines, Lobbying and Interest Representation Register, LIVR-00193

Main lobbying topics

The following are the main topics of the Lufthansa Group that are subject to its lobbying activities:

Aviation regulation and passenger rights:

• Reform of EU Air Passenger Rights Regulation 261/2004 according to the 2013 Commission proposal
• Maintain European regulation on common rules for slot allocation at airports
• Maintain advance payment practice for flight ticket purchases
• Make provision of aircraft data to airlines mandatory
• Create legal basis for modernising aviation security controls

Sustainable Aviation Fuel (SAF) and climate policy:

• Finance SAF quota through uniform levy
• Expand free SAF certificates
• Use aviation tax for SAF promotion
• Introduce European support strategy for SAF
• Introduce Book & Claim mechanism for SAF use
• No introduction of a kerosene tax under the Energy Tax Directive
• Introduce prioritised air traffic control clearances based on "Best Equipped Best Served" (BEBS) principle
• Consider including aviation in German and European carbon management strategy
• Limit non-CO2 effects in EU Emissions Trading System (ETS) to intra-European flights
• Delete national quota for Power-to-Liquid fuels in Federal Immission Control Act (BImSchG)
• Examine application of Carbon Border Adjustment Mechanism (CBAM) in aviation

Airspace and infrastructure:

• Introduce single European airspace with politically independent European regulatory authorities
• Connect German airports to high-speed rail routes
• Maintain flight route technology ADS-C EPP obligation

Operational and regulatory matters:

• Revise EU Regulation 1069/2009 (health rules for animal by-products not intended for human consumption)
• Make employment references transmittable via text form
• Make essential contractual terms transmittable in text form
• Transpose EU Corporate Sustainability Reporting Directive (CSRD) unchanged into German law
• No further increase in location costs through state fees
• Digitalisation of data exchange including with authorities along the air cargo transport chain

Employment and labor law:

• Close EU legislative gaps in working conditions
• Reform strike law regarding announcement periods, emergency service agreements and mandatory conciliation procedures

Payment Practices

Working Capital and Payment Management

The Lufthansa Group implements comprehensive working capital management practices that include strategic payment optimization:

Payment Terms Optimization:

• Optimising payment terms with suppliers as key component of working capital management
• Improvements to procurement processes supporting better payment coordination
• Payment practices designed to support cash flow generation and financial stability

Cash Flow Management Integration:

• Working capital management to be further intensified including payment practice improvements
• Strict receivables management coordinated with payment obligations
• Maintenance of inventories optimization particularly at Lufthansa Technik affecting payment cycles

Supplier Payment Framework

Strategic Payment Management:

• Payment terms negotiated as part of supplier relationship management
• Balance between company cash flow needs and supplier partnership maintenance
• Long-term supplier relationships supported through fair payment practices
• Procurement process improvements streamlining payment workflows

Financial Stability Considerations:

• Payment practices designed to support generation of strong free cash flows
• Working capital management as key lever for financial performance
• Payment timing coordinated with focused investing activities and cash management
• Risk assessment of supplier financial stability affecting payment terms

Operational Payment Practices

Customer Payment Processing:

• Automated refund and compensation payments in response to regulatory requirements
• Digital customer portal enabling quick payment processing for additional services
• Self-service payment options for rebookings, additional products, and services
• Advance payments received from customers for flight documents managed as working capital

Employee Compensation Payments: Comprehensive wage improvements implemented in 2024:

• Inflation bonuses paid across all major employee groups
• Gradual salary increases implemented according to collective agreement schedules
• Holiday pay increases and additional benefit payments
• Multi-year payment schedules providing predictability for both company and employees

Financial Instrument Management

Debt Service and Interest Payments:

• Interest and dividend payments affecting net indebtedness calculation
• Lease financing payments as part of comprehensive payment obligations
• Bond and debt service payments managed through diversified financing strategy
• Rule-based processes for financial payment obligations

Investment and Capital Expenditure:

• Net capital expenditure of EUR 2,392m in 2024 requiring systematic payment management
• Advance and final payments for aircraft and components representing major payment commitments
• Sale-and-lease-back transaction payments affecting cash flow timing
• Investment project payments coordinated with value creation objectives

Regulatory and Compliance Payments

Tax and Regulatory Obligations:

• EU ETS certificate costs increased by EUR 134m requiring systematic payment management
• Germany's air traffic tax increase (effective May 2024) affecting payment obligations
• Fees and charges payments as part of operational cost structure
• Multiple jurisdiction tax and regulatory payment obligations

Consumer Protection Payments:

• Automated refund processing in compliance with consumer protection requirements
• Compensation payments for flight irregularities and service issues
• Customer service related payments through digital channels

Performance and Efficiency Measures

Payment Process Improvements:

• Finance Transformation Programme includes payment process modernization
• Standardised Group-wide financial processes for payment efficiency
• Process, IT and industry standards implementation to reduce complexity
• Digital transformation of payment workflows and systems

Cash Management Strategy:

• Minimum liquidity of EUR 8-10bn maintained requiring sophisticated payment timing
• Available liquidity of EUR 11.0bn at year-end 2024 supporting payment obligations
• Strategic liquidity reserve management coordinating payment capabilities
• Revolving credit facilities providing payment flexibility for capital efficiency

The Group's payment practices are integrated into its overall financial strategy of generating strong free cash flows while maintaining operational efficiency and strong supplier relationships.