Deutsche Lufthansa

The role of the administrative, management and supervisory bodies

Reference: pages 112-118; qualification matrices T048 (page 114) and T049 (pages 115-117).

"The Executive Board is responsible for managing the Company and defining its strategic direction. The Supervisory Board appoints the Executive Board, advises it on the management of the Company and monitors its activities" (page 112). The Executive Board had five members at end-2025; the Supervisory Board "comprises 20 people and its members consist of ten shareholder representatives and ten employee representatives, as per the German Co-determination Act" (pages 113-114).

Sustainability allocation (pages 112-113): "The Sustainability division is represented by the Chief Technology Officer on the Executive Board"; the CTO "is explicitly entrusted with monitoring environmental, climate and social impacts", and Corporate Responsibility reports directly to the CTO. Corporate Controlling reports to the CFO and is "responsible for managing financial and sustainability risks".

The Supervisory Board has an ESG Committee of four members, in 2025 Erich Clementi (Chairman), Sara Grubisic, Marvin Reschinsky and Angela Titzrath, which "meets at least twice a year".

Diversity datapoints: Executive Board 20% female / 80% male, average age 54 (page 114); Supervisory Board 40% female / 60% male, average age 56, independence confirmed for all members (pages 115-117).

Information provided to and sustainability matters addressed by the undertaking's bodies

Reference: pages 118-119.

"The management and supervisory bodies of the Lufthansa Group, including the responsible committees, are informed several times a year about material impacts, risks and opportunities relating to ESG topics, as well as about sustainability reporting." Reporting-project managers at the first management level "were informed about progress six times in 2025 and made decisions in this context" (page 118).

ESG Committee: "Two meetings of the ESG Committee were held during the reporting year", covering the ESG strategy and framework, ESG performance, the ESG HR strategy, the CSRD reporting process and a CSRD benchmark. ESG focus topics were "the decarbonisation pathway, the status and cost effects of sustainable aviation fuel (SAF), as well as Green Fares and strategic approaches to stronger customer engagement" (page 118).

Where matters were addressed (page 119): the Executive Board, Group Executive Committee, Group Policy Committee and the ESG and Audit Committees. Core topics were "climate change and its impact on business activities, compliance with social standards within the supply chain, and issues relating to good corporate governance and compliance", with the decarbonisation pathway and SAF procurement "once again the focus of attention this year". Targets are reviewed in a "Strategic Performance Dialogue" chaired by the CTO.

Integration of sustainability-related performance in incentive schemes

Reference: pages 119-120; cross-referenced under E1 on page 162.

One-year variable remuneration (STI): "20% of the one-year variable remuneration is based on overall and individual business and sustainability targets, for which the Supervisory Board sets annual areas of focus." Since 2023 the "Customers" and "Employees" targets "each account for 10% of the one-year variable remuneration". For 2025, the Customers parameter was "the flight schedule stability rate of the Lufthansa Group's Network Airlines ... based on flight cancellations within 90 days prior to departure", excluding strikes and geopolitical events; the Employees parameter is the Engagement Index (page 119).

Long-term variable remuneration (LTI): subject to a four-year assessment period and "made up of 20% strategic and sustainability targets". "The reduction of specific CO2 emissions has been defined as a core focus for the long-term variable remuneration since 2022", measured in "grammes CO2 per tonne-kilometre transported, in line with the target system for the validated SBTi targets" (page 120). Page 162 confirms this environmental objective "has a weighting of 20% in the assessment of the level of target achievement for the LTI 2025".

Supervisory Board remuneration is fixed only: "Members do not receive attendance fees or variable remuneration" (page 120).

Statement on due diligence

Reference: pages 121-122, table T050 "ESRS 2 GOV-4 | 30 & 32 Statement on due diligence in 2025".

The statement is given as a concordance mapping each of the five core elements of due diligence to the disclosures that cover it, with a column flagging whether the disclosure "refers to people and/or the environment" (pages 121-122):

• a) Enshrining due diligence in governance, strategy and business model - GOV-2, GOV-3, SBM-3 and the topic-level SBM-3 sections for E1, S1, S2 and S4.
• b) Integration of affected stakeholders - SBM-2, GOV-2, IRO-1, E1-2, E5-1, S1-2, S2-2, E2-1, S1-1, S2-1, S4-1, S4-2, G1-2, G1-1.
• c) Identification and assessment of negative impacts - IRO-1 ("Material impacts, risks and opportunities of the Lufthansa Group were reviewed" and "The connection with risk management was further developed") plus SBM-3 at Group level and for E1, S1, S2, S4.
• d) Adopting measures to mitigate negative impacts - E1-1, E1-3, E2-2, E5-2, S1-4, S2-4, S4-4, G1-1, G1-2, G1-3, G1-4.
• e) Tracking efficacy and reporting - E1-4 to E1-7, E1-9, E2-3, E2-4, E5-3, E5-4, S1-5, S1-9, S1-14, S1-16, S1-17, S4-5, G1-4, G1-5, G1-6.

The E1 row points specifically to "ESRS E1 Climate change - Resilience analysis has been updated and resistance to climate change has been analysed" (page 121).

Risk management and internal controls over sustainability reporting

Reference: pages 123-125.

"The Lufthansa Group is continuing the Group-wide implementation of a non-financial internal control system (N-ICS) as well as a uniform risk management methodology ... These processes are currently being standardised." The N-ICS "contains principles and processes from the framework of the Committee of the Sponsoring Organizations of the Treadway Commission (COSO)" (page 123).

2025 progress (page 123): "the scope of the N-ICS remained largely unchanged compared with the previous year. Structural progress in implementation was achieved in particular through the further development of the policy for defining the audit scope for relevant data points and the systematic inclusion of additional IT systems in the N-ICS."

Risk integration (page 123): "Since the beginning of the current reporting year, ESG risks assessed as material have been transferred into the Lufthansa Group's established risk management process", assessed net rather than gross.

Candid limitations (pages 124-125): "Material risks in the reporting relate to incompleteness or inaccuracies in the report, as well as approvals that have not yet been obtained." Documentation of the mitigating controls "is currently being established and is being expanded and implemented step by step", and the 2025 ICS effectiveness report still focused on the financial ICS.

Strategy, business model and value chain

Reference: pages 110-111 (value chain chart C26), 125-126 (tables T051, T052).

The Group operates five main Passenger Airlines (Lufthansa Airlines, SWISS, Austrian Airlines, Brussels Airlines, Eurowings) plus Discover Airlines and Edelweiss, a stake in ITA Airways, Lufthansa Cargo, Lufthansa Technik, Lufthansa Systems and Lufthansa Aviation Training, from five hubs (Frankfurt, Munich, Zurich, Vienna, Brussels) (page 125).

Revenue by ESRS sector in 2025 (T052, page 126):

Employees by region (T051, page 125): total 103,255 (2024: 101,422), of which Germany 67,091, other Europe 27,690, Asia/Pacific 4,760, North/Central America 2,723, Middle East/Africa 765, South America 226.

Strategic targets named under SBM-1 (page 126): "By 2030, the Company aims to achieve a net reduction in CO2 of 50% in comparison with 2019"; phase-out of single-use plastic and aluminium on board; "a 25% share of women in management positions by the end of 2025"; and "an employee engagement index of 3.6 in 2025". The Group invokes the intellectual-property and ongoing-negotiations exemptions to omit certain information (page 111).

Interests and views of stakeholders

Reference: pages 127-129; dialogue formats table T053 (page 128).

Eight stakeholder groups are identified, including "Nature" alongside customers, capital market, politics, science, employees, suppliers and society (page 127). "In 2023, a comprehensive stakeholder survey was conducted in order to obtain more in-depth findings. By involving more than 10,000 external individuals, external perspectives were incorporated" (page 127).

Formats (T053, page 128) run from employee surveys, works council conferences and "frankly speaking" sessions with the CEO, through Capital Markets Day and investor roadshows, to the Airport/Region forum in Frankfurt and local aircraft noise committees.

How views feed strategy (pages 128-129): "The results of the stakeholder involvement were used in the Lufthansa Group's materiality assessment and its validation in the 2025 reporting year." Internal experts "represented and incorporated the perspectives of stakeholders as part of the validation of the materiality assessment in 2025" - the 2023 survey was not repeated.

Examples of business-model adaptation are holiday-route expansion, intermodal rail and bus integration, and the extension of Green Fares to intercontinental routes in December 2024. "Overall, the share of bookings with a more sustainable flying option rose in the reporting year from 4% to around 5%, which represents relative growth of 25%" (page 129).

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: pages 130-148; table T054 (pages 130-145); changes versus 2024 on page 146; resilience on pages 146-148.

T054 sets out 70 individually typed IRO rows across 21 aggregated aspects in eight material standards. Each row carries its type, value-chain allocation, time horizon, the influence on the business model, the intended response and any current financial effect. Aspects include E1 extreme weather events, regulatory and market risks, CO2 emissions, contrails and energy efficiency; E2 noise pollution; E5 resource inflows; nine S1 aspects from secure and attractive employment to data security; S2 human and labour rights in the value chain; six S4 aspects; and seven G1 aspects.

Changes versus 2024 (page 146) are flagged in the table and explained: E1 IROs "were restructured"; the E5 sub-topic "Resource outflows in connection with products and services" was classified as not material; in S1 "'Adequate wages' was reassessed ... and is no longer material" and a new aspect "Secure and attractive employment" absorbed the former "Social protection" aspect; in G1 "In the area of 'Animal welfare', neither material risks nor material impacts were identified".

Only the ETS-exposed aspects carry a quantified current financial effect ("Higher costs due to expected price trend for ETS certificates"); every other row states "No current financial effects" (pages 130-145).

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

Reference: pages 148-151.

"In order to identify, evaluate and monitor its material impacts, risks and opportunities ... the Lufthansa Group follows a four-stage process that was first developed and implemented in 2024 ... In the 2025 reporting year, the Lufthansa Group carried out a validation of the previous year's results. However, the basis was still the materiality assessment process initially carried out in 2024" (page 148).

Method (pages 148-150): impacts were measured "inside out" on a 1-to-4 severity scale gross of mitigating measures; "When determining the materiality of potentially negative impacts in relation to human rights, the degree of severity takes precedence above probability of occurrence." Risks and opportunities were measured "outside in" on a 1-to-5 extent scale with named probability bands. Thresholds "are the same as the thresholds applied for external reporting by the Lufthansa Group ERM system".

Stated limitation (page 150): "the processes for identifying, assessing and managing ESG opportunities are still not fully integrated into the overall management system." No site-level analysis was run for E2-E5 "because the Lufthansa Group only operates a very limited number of production processes at its sites" (pages 150-151).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: pages 152-155, table T055 "ESRS 2 IRO-2 | 56 Disclosure requirements (DRs) in ESRS covered by the Lufthansa Group's sustainability statement in 2025"; EU-legislation datapoint list T056 on pages 155-159.

T055 is a genuine ESRS content index. It lists each standard, the disclosure requirement code and the chapter that covers it. The DRs listed are:

• ESRS 2 - BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2
• ESRS E1 - E1-1, E1-2, E1-3, E1-4, E1-5, E1-6, E1-7, E1-9 (plus cross-references to ESRS 2 GOV-3, SBM-3, IRO-1). E1-8 is absent.
• ESRS E2 - E2-1, E2-2, E2-3, E2-4, E2-6. E2-5 is absent.
• ESRS E5 - E5-1, E5-2, E5-3, E5-4, E5-6. E5-5 is absent.
• ESRS S1 - S1-1 to S1-6, S1-8, S1-9, S1-14, S1-16, S1-17. S1-7, S1-10, S1-11, S1-12, S1-13 and S1-15 are absent.
• ESRS S2 - S2-1 to S2-5; ESRS S4 - S4-1 to S4-5; ESRS G1 - G1-1 to G1-6
• No ESRS E3, E4 or S3 rows appear at all.

T056 lists the datapoints derived from other EU legislation with a column headed "Chapter/sub-chapter or not material"; the E3-1, E3-4, E4-2, SBM-3-E4 and E5-5 rows are all marked "Not material" (pages 157).

Count check: the table title says 56 DRs; removing the 13 repeated ESRS 2 cross-reference rows from the 70 printed rows leaves 57 distinct DRs, one more than the stated figure. The discrepancy is not explained in the report.

Transition plan for climate change mitigation

Reference: pages 161-162.

"The Lufthansa Group's Climate Transition Plan is closely linked to financial planning. Fleet renewal plays a critical role in the Lufthansa Group's climate strategy and requires substantial capital expenditure every year. The level of fuel efficiency gains and GHG emission reductions depends on investment levels and the availability of new aircraft." The plan "was developed alongside the corporate strategy and was presented and approved in a special meeting of the Executive Board" (page 161).

Scope limitation stated: "While the current Transition Plan focuses on flight operations, additional decarbonisation measures for ground operations, including buildings and vehicles, are currently under development" (page 162). "CO2 intensity (SBTi KPI) is tracked annually" (page 162).

Taxonomy link (page 161): for Activity 6.19 the Group reports "EUR 4,666m in taxonomy-eligible capital expenditure, representing 86% of total capital expenditure", of which "EUR 3,752m or 69% is taxonomy-aligned". However, "A CapEx plan relating to this capital expenditure is not disclosed in the taxonomy report".

"The Lufthansa Group is not exempt from the EU's agreed climate benchmarks under the Paris Agreement" (page 162).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (pages 162-163). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risks classified (page 162). Four transition risks are named: rising CO2 prices under the EU ETS and CORSIA; rising kerosene prices from upcoming fuel legislation; "Lack of availability and high prices for SAF, accompanied by mandatory, continuously rising blending quota from 2025 onwards"; and conventional fuel price fluctuations. One physical risk: "Disruptions in operations and consequently higher current costs as a result of heatwaves".

Physical scenario analysis (page 163): two IPCC pathways, "one pathway with low emissions (SSP1-2.6 ...) and one pathway with high emissions (SSP5-8.5, fossil-fuelled development scenario)", using Fathom Global 3.0 for flood risk and ISIMIP3b CMIP6 for heatwaves. "a list of 28 climate risks was evaluated, of which 18 (previous year: 15) were selected", plus three aviation-specific risks, across "33 regions and sites (previous year: 25)" for the horizons 2025, 2030 and 2050.

Transition scenario analysis (page 163): the IEA "Stated Policies Scenario" and "Net Zero Scenario 1.5C"; ten transition risks and opportunities shortlisted, one more than in 2024.

Gap: no global average temperature projection per scenario is stated; the report notes uncertainties remain "particularly in the evaluation of flight routes".

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (pages 146, 164-165). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"The climate resilience analysis was reviewed and, where necessary, updated on the basis of the results of the climate scenario analysis for the 2025 financial year" (page 164). Scope covers own operations plus the upstream and downstream value chain, "passenger and freight air transport, as well as maintenance and repair".

Result (page 146): "Following the analysis of current and planned measures and the assessment of short-term net risks and opportunities ... the Lufthansa Group can be assessed as resilient to the risks." Assumptions (page 164): "It is assumed that demand for air travel will continue to increase ... and that the global economy and macroeconomic trends will remain stable", plus emissions and fuel prices, transport performance and CO2 intensity.

Uncertainty acknowledged (page 164): "To further reduce any uncertainties ... such as whether political actions will have as much impact as assumed, a financial evaluation of the identified qualitative climate risks will be carried out in the long term." Stakeholders were involved in the previous year only.

Adaptive capacity (pages 164-165): heatwave measures "continue to be considered sufficient"; on transition risks the Group "currently considers itself sufficiently capable of adapting".

Policies related to climate change mitigation and adaptation

Reference: pages 165-166.

Adaptation gap stated up front: "At present, there are therefore no specific policies relating to climate change adaptation" (page 165).

Four-pillar climate change mitigation strategy (pages 165-166, chart C28). Aligned to the IATA framework defined in 2007, the four areas of action are technological progress, improved infrastructure, operational measures and economic instruments. "the use of renewable energy as well as energy and fuel efficiency form the basis of the conceptual approach to climate change mitigation."

Scope and monitoring: "The strategy applies to all the consolidated airlines in the Lufthansa Group ... The monitoring to assess the success of the strategy consists of an annual measurement of greenhouse gas emissions compared with the reduction target by comparing the emissions model with the actual performance figures on fuel consumption and revenue tonne-kilometres (RTK), the sale of climate change mitigation projects through CO2 credits (offsetting) and the use of SAF." The Executive Board "bears ultimate responsibility" (page 165).

Ground operations energy management (pages 165-166): introduced in 2024, focused on "energy efficiency, renewable energy, energy procurement and ground mobility", drawing on EMAS and ISO 50001, with progress "monitored annually as part of the respective certification processes".

Actions and resources in relation to climate change policies

Reference: pages 166-169.

Fleet renewal - "the most important lever" (pages 166-167): "The Lufthansa Group fleet was expanded by 23 (previous year: 18) new aircraft in 2025 ... A total of 21 (previous year: 4) aircraft have been removed." Since 2019 the Group "has more than doubled the proportion of its fleet fitted with the latest technology to 25% (181 aircraft)", expects "approximately 45 modern aircraft" in 2026 and holds a backlog of "around 220 aircraft". "In total, EUR 4,666m (previous year: EUR 3,912m) was invested in fleet renewal in 2025."

Retrofit (page 167): AeroSHARK riblet films cut drag "and thus their kerosene consumption by around 0.8%"; at end-2025 "the Lufthansa Group fleet had a total of 21 (previous year: 17) Boeing 777s fitted with AeroSHARK".

OPS Sustainability Program (page 168): "In the reporting year, 81 (previous year: 91) emission-reduction projects were pursued across the Group", which "made it possible to permanently avoid another 67.8 thousand (previous year: 37 thousand) tonnes of CO2 emissions", saving "approximately 21.7 thousand (previous year: 12 thousand) tonnes" of kerosene. The programme "was extended until 2028".

Ground (page 169): "In July 2025, several Group companies, including Deutsche Lufthansa AG and Lufthansa Technik AG, were certified in accordance with ISO 50001." The time horizon for ground actions "is long term and extends until 2045".

Targets related to climate change mitigation and adaptation

Reference: pages 169-170.

"The SBTi validation in 2022 made the Lufthansa Group the first airline group in Europe ... with a scientifically verified CO2 reduction target" (page 169). The target: "reducing its carbon intensity, i.e. its CO2 emissions in grammes of CO2 per revenue tonne-kilometre (passenger and freight), by 30.6% from 2019 to 2030", aligned with "well below two degrees" and covering "Scope 1 as well as Scope 3, Category 3".

Supplementary: "a net-zero target for 2050 and a net-emissions target of -50% defined for 2030 compared with 2019 to help limit global warming to only 1.5C"; plus renewable-only ground electricity in DE, AT and CH.

Lever contributions to the 2030 target (page 170): fleet renewal -15.3% per RTK; operational efficiency -3.9%; SAF -3.4%.

Progress and shortfall (page 170): the combined reduction per RTK versus 2019 "amounted to 7.1% (previous year: 3.8%)". But "the level of reduction currently remains below the expectations defined at the time the target was set", due to "delays in the delivery of modern aircraft" and conflict-driven airspace restrictions. "A revalidation of the SBTi target is planned for the 2026 financial year."

Gaps: "The Lufthansa Group has not yet defined targets for other climate-relevant non-CO2 gases", and the 2030 ground-mobility ambition "has not been verified as compatible with the 1.5-degree target" (page 170).

Energy consumption and mix

Reference: page 171, table T058 "ESRS E1-5 | AR34 Energy consumption and mix in 2025".

Comparability caveat (page 171): "the methodology used to calculate SAF volumes was adjusted compared with the previous year due to regulatory requirements under RefuelEU Aviation. Whereas in the previous year, SAF energy consumption was reported based on volumes sold, in the current reporting year, it is based on delivered SAF volumes." The sevenfold rise in renewable fuel is therefore not like-for-like.

The Group received "EUR 13m under the EU Emissions Trading System (EU ETS) to co-finance the use of eligible SAF". Energy intensity in high-climate-impact sectors "amounted to 2.7 kWh per euro of revenue in 2025 (previous year: 2.7 kWh per euro of revenue)".

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 171-173, tables T059 and T060.

Largest Scope 3 categories in 2025: fuel and energy-related activities 6,346; purchased goods and services 3,209; capital expenditure 2,645 (+116%); upstream transport and distribution 2,455 (+35%). "For Scope 3, Category 15, the carbon footprint shows significant deviations compared with the previous year due to the first-time inclusion of the equity interest in ITA acquired in 2025" (page 173). Categories 8, 10, 11, 12 and 14 are reported as n/a.

Biogenic emissions from SAF combustion: "440,372 tonnes of carbon dioxide equivalents (t CO2e) in Scope 1 (previous year: 63,741 t CO2e) and 53,020 t CO2e in Scope 3", collected for the first time in 2025 (page 173).

Intensity (T060, page 173): 1,143 t CO2e per EUR m net revenue location-based (2024: 1,145) and 1,142 market-based (2024: 1,143). The footprint "is verified annually by an independent external audit organisation" (page 171).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: pages 173-174, table T061.

The disclosure covers carbon credits supporting the voluntary net target. "Beyond its SBTi target, the Lufthansa Group aims to reduce its net CO2 emissions by 50% by 2030 compared with 2019. Support for climate change mitigation projects that avoid or remove CO2 emissions is included as part of this approach and makes a material contribution to achieving this climate target" (page 173).

"2% (previous year: 3%) of the retired certificates relate to projects carried out in Europe. Moreover, the Lufthansa Group has not retired any CO2 certificates that fall under Article 6 of the Paris Climate Agreement" (page 174).

Partners named are myclimate, Climate Austria, SQUAKE, Climeworks, Ceezer and ClimatePartner. "Investments in operational measures are prioritised over CO2 credits", but "CO2 credits are therefore indispensable as a compensation instrument in order to achieve the emissions targets" (page 173).

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Reference: page 174; basis of preparation page 108.

The disclosure requirement is listed in the Group's ESRS content index (page 153), and the substance the company gives is an explicit invocation of transitional relief, quoted in full:

"The Lufthansa Group makes use of the transitional relief provided for under the delegated 'Quick Fix' act and therefore refrains from disclosing the anticipated financial effects within the meaning of ESRS E1-9" (page 174).

This follows from the basis of preparation: "For the 2025 financial year, reporting is likewise based on the ESRS and, in part, on the application of the delegated act amending Delegated Regulation (EU) 2023/2772 ('Quick Fix')" (page 108). The same wording is used for E2-6 (page 177) and E5-6 (page 184).

What is disclosed instead. No monetary amounts are given for assets at material physical risk or for potential future ETS liabilities. The report does state that "Physical climate risks were not reflected in the financial reporting in the reporting year. The climate transition risks identified as material are consistent with those considered in the financial reporting" (page 162), and the IRO table attaches the effect "Higher costs due to expected price trend for ETS certificates" to three E1 aspects without quantifying it (pages 130-132).

Policies related to pollution

Reference: pages 174-175, chart C29 "Active Noise Abatement".

E2 materiality is confined to aircraft noise. "On the broad topic of pollution, the Group primarily targets active noise abatement. In this context, it seeks to balance the Company's objectives with those of the local communities living near airports" (page 174).

The policy is a five-pillar strategy for active noise abatement (page 175): investments in quieter aircraft; noise-reducing technologies for the existing fleet; participation in noise research; development of optimised flight procedures and routes; and dialogue with residents in airport regions.

"With this five-pillar strategy, the Lufthansa Group focuses on reducing the negative impacts of noise on local communities and other stakeholders. At the same time, the strategy serves as a basis for managing identified risks, such as costs arising from necessary adjustments to noise abatement regulations or from the avoidance of local limit value exceedances that could result in fines" (page 175).

Governance: the Infrastructure & System Partnerships department is "the central coordinating unit within the Group on the issue of aircraft noise" and represents the Group in the Airport and Region Forum in Frankfurt. The approach aligns with "the Balanced Approach of the International Civil Aviation Organization (ICAO) ... part of EU Regulation 598/2014" (page 175).

Actions and resources related to pollution

Reference: pages 175-176.

"The measures described below are implemented continuously. Accordingly, no fixed time horizons have been set for them, except for research and development projects. Here the time horizons typically span between one and five years" (page 175).

• Fleet modernisation - "The highest priority measure for reducing aircraft noise at source". Aircraft entering service in 2025 (A320neo, A321neo, A350-900, B787-9) "have modern engines and are much quieter than comparable older aircraft types" and meet ICAO noise requirements (pages 175-176).
• Retrofit - aircraft with vortex generators "are up to four decibels quieter on their approach, so the Company pays lower noise fees in Frankfurt". The A320-family programme completed at end-2024, and "No retrofitting of the existing fleet was carried out in 2025" (page 176).
• Noise research - "Lufthansa Airlines supported the German Aerospace Center in developing the new LNAS departure functionality by conducting practical tests of this functionality on its A330 fleet in summer 2025" (page 176).
• Flight procedures - RNP X segmented-approach trials launched at Frankfurt in 2025; a refined Berlin departure route "was implemented by DFS in September 2025"; and trial operations of the modified "CINDY-S" departure route at Frankfurt "were launched in July 2025" to avoid populated areas north of Darmstadt (page 176).

Targets related to pollution

Reference: page 177.

"The Lufthansa Group pursues the long-term objective of reducing aircraft noise without a defined time limit. The focus is on reducing noise directly at source, as well as on the continuous optimisation of flight procedures and routes in cooperation with system partners" (page 177).

No quantified, time-bound noise target is set. Instead effectiveness is tracked: "Since 2012, the Lufthansa Group has played an active role in the Alliance for Active Noise Abatement at its Frankfurt location. Since then, the Company, together with stakeholders in the 'Forum Flughafen und Region', has monitored the effectiveness of active noise abatement measures." "The effectiveness review, based on determining the proportion of the fleet that cumulatively falls at least 10 decibels below the ICAO Chapter 3 noise limits, is conducted annually with no defined end date."

The company states it is considering setting one: "the Company is currently evaluating whether setting a target based on its existing active noise abatement indicator would serve as an effective management tool for noise reduction. This metric is directly linked to the status of fleet modernisation" (page 177).

Pollution of air, water and soil

Reference: page 177; calculation method page 185 onwards.

The Group reports one entity-specific pollution metric rather than E-PRTR pollutant quantities: the active noise abatement indicator.

"Noise reduction improvements resulting from fleet modernisation are measured using a company-specific performance indicator. This active noise abatement indicator reflects the proportion of the fleet that falls below specified noise limits, depending on both the composition of the Lufthansa Group fleet and ongoing modernisation efforts. Since fleet renewal is a long-term process, annual changes remain minimal. As of 25 October 2025, 99.6% (previous year: 99.6%) of the aircraft - and thus, as in previous years, virtually the Group's entire operating fleet - met this criterion" (page 177).

The threshold is the ICAO Chapter 3 noise limits less at least 10 decibels cumulatively (page 177).

In the EU-legislation datapoint table T056 the E-PRTR row, "ESRS E2-4 Amount of each pollutant listed in Annex II of the E-PRTR Regulation ... emitted to air, water and soil, Paragraph 28", is cross-referenced to this same chapter rather than answered with pollutant tonnages (page 156). No microplastics, air, water or soil pollutant quantities are disclosed; the materiality assessment found no site-level pollution IROs "because the Lufthansa Group only operates a very limited number of production processes at its sites" (page 150).

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

Reference: page 177; basis of preparation page 108.

E2-6 is listed in the Group's ESRS content index (page 153). The disclosure consists of an explicit invocation of transitional relief, quoted in full:

"The Lufthansa Group makes use of the transitional relief provided for under the delegated 'Quick Fix' act and therefore refrains from disclosing the anticipated financial effects within the meaning of ESRS E2-6" (page 177).

This rests on the basis of preparation: "For the 2025 financial year, reporting is likewise based on the ESRS and, in part, on the application of the delegated act amending Delegated Regulation (EU) 2023/2772 ('Quick Fix')" (page 108). Identical wording is used for E1-9 (page 174) and E5-6 (page 184).

No monetary amounts are therefore given for noise-related financial effects. The IRO table records the noise risk qualitatively - amended or new noise abatement regulations "may result in significant financial strain for the Lufthansa Group", and non-compliance could bring legal action "with financial and reputational consequences" - but the current financial effects column reads "No current financial effects" for all three E2 rows (page 133).

Policies related to resource use and circular economy

Reference: pages 178-180.

"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 put into practice by the individual business segments in various ways" (page 178).

Passenger Airlines (pages 178-179): guidelines under a global waste policy, based on the R-strategies and the EU waste hierarchy (2008/98/EC), aim "to promote the shift away from the use of virgin resources and towards renewable, recycled or recyclable materials". Tenders require "only materials that do not contain any single-use plastic or single-use aluminium ... and that comply with applicable regulations such as the PPWR and the European Deforestation Regulation (EUDR)".

Lufthansa Technik (page 179): "As a maintenance organisation, Lufthansa Technik is obliged to operate in compliance with the requirements of European Union Aviation Safety Agency (EASA) Part-145 ... Consequently, Lufthansa Technik does not make the decisions regarding the use of recycled materials." A component leasing pool keeps parts in circulation.

Lufthansa Cargo (page 180): a circular concept for loading aids and equipment, "increasing recycling rates by substituting materials, introducing closed-loop systems and conserving resources", with binding circular requirements in supplier contracts.

Actions and resources related to resource use and circular economy

Reference: pages 180-182.

Replace (pages 180-181): "In the reporting year, Brussels Airlines replaced single-use aluminium trays for salads and desserts with bagasse trays in Economy Class." "Since September 2025, SWISS and Edelweiss have packaged blankets and headphones in paper instead of plastic. Blanket and headphone packaging across Lufthansa Airlines, SWISS, Austrian Airlines, Brussels Airlines, Discover Airlines and Edelweiss has now been converted from plastic to paper."

Reduce (page 181): the AI-supported mobile "Tray Tracker" analyses food consumption on incoming flights; on that basis "meal loading was adjusted during the reporting year on night flights from Boston and Bangkok at SWISS and Austrian Airlines to reduce food waste".

Recycle (page 181): PET recycling begun by Eurowings at Dusseldorf "was expanded in the 2025 financial year to the stations in Stuttgart, Berlin, Nuremberg and Mallorca". "Lufthansa Airlines transferred a total of 52,684 tonnes (previous year: 44,886 tonnes) of textiles to recycling processes."

Lufthansa Cargo (pages 181-182): the return-to-manufacturer scheme for load-securing straps "has become a standard process"; but the lighter pallet net "rollout to larger pallets could not be implemented in 2025, as the lighter nets do not yet fully meet the higher quality and safety requirements ... Implementation is therefore planned for 2026".

Targets related to resource use and circular economy

Reference: pages 182-183.

Single-use items (page 182): "Since 2025, the Lufthansa Group Passenger Airlines have been pursuing the objective of ensuring that all customer-facing single-use plastic and aluminium items are either recyclable or made from renewable materials", scheduled "for completion by 2030"; "In total, 588 items were identified for replacement". "As per European Union regulations, the targets set are voluntary targets."

Food waste - achieved (page 182): the target of "reducing food waste on short-haul flights by 50% by 2025 compared with the base year 2019 ... was achieved in the reporting year, with a reduction of 54%".

Lufthansa Technik - missed (pages 182-183): a 75% global recycling rate target by end-2025, set in 2017 against a 2018 base of 51%. "In 2025, the recycling rate reached 54% ... the objective of 75% within the Lufthansa Technik Group was not achieved", due to "ongoing technical and organisational challenges in the recovery of certain waste streams". "Following the end of the 2025 target horizon, no new recycling rate targets have yet been defined."

Lufthansa Cargo (page 183): target of 40% recycled materials at the Frankfurt hub by end-2025, from 35% in 2020; "the share reached 43%" in 2024, but the 2025 values "were not yet available at the time of the Annual Report's release".

Resource inflows

Reference: pages 183-184.

Resource inflows are described qualitatively by segment rather than by weight. Passenger Airlines use "food and beverages, single-use items (such as plastic packaging, aluminium trays, film, lids, serviettes ... beverage cartons, aluminium cans, glass and cardboard) and reusable items (such as cutlery, crockery, glasses, textiles such as pillows and bedding, comfort amenities and headphones)" (page 183).

Lufthansa Technik uses "finished parts (mechanical and electrical components, engine parts and fibre-reinforced composites), semi-finished products, hazardous substances as per the Globally Harmonised System". "Products used by Lufthansa Technik may contain small quantities of tin, tungsten, tantalum and gold ... As the products are procured as complete units, there is no direct influence over their material composition" (page 183).

The one quantified metric (page 184): a company-specific indicator based on the IATA Airline Sustainability Reporting handbook. "In 2025, a total of 588 items (previous year: 721 items) made from single-use plastic or single-use aluminium were in use on board in the Passenger Airlines, of which 293 items (previous year: 263 items) were replaced." At Lufthansa Cargo only 11 such items are in use, none replaced in 2025.

No total weight of materials used, and no share of biological or secondary reused/recycled components, is disclosed.

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

Reference: page 184; basis of preparation page 108.

E5-6 is listed in the Group's ESRS content index (page 153). The disclosure is an explicit invocation of transitional relief, quoted in full:

"The Lufthansa Group makes use of the transitional relief provided for under the delegated 'Quick Fix' act and therefore refrains from disclosing the anticipated financial effects within the meaning of ESRS E5-6" (page 184).

The basis of preparation records that "For the 2025 financial year, reporting is likewise based on the ESRS and, in part, on the application of the delegated act amending Delegated Regulation (EU) 2023/2772 ('Quick Fix')" (page 108). The identical formulation appears for E1-9 (page 174) and E2-6 (page 177).

No monetary amounts are given. The IRO table describes the E5 risk qualitatively - "A significant rise in current and production costs may occur due to new or amended global government regulations" on single-use plastics, electronic waste and extended producer responsibility - and records "No current financial effects" (page 134). The Passenger Airlines "are actively preparing for the implementation of the planned EU regulations on single-use plastics, which are currently expected to enter into force in 2030" (page 147).

Policies related to own workforce

Reference: pages 203-205.

HR strategy (page 203). The HR strategy "focuses on the following six pillars: Modern and flexible career paths; New forms of work; A contemporary leadership culture and diversity; Sustainable employability; Trust-based collective bargaining partnerships; Competitive staff costs." It "applies worldwide to all employees of the Lufthansa Group", with the Executive Board bearing ultimate responsibility.

Human rights policy statement (page 204). "The Lufthansa Group's policy statement on the German Supply Chain Due Diligence Act (LkSG) from 2023, updated in November 2025, outlines its human rights strategy." It is reviewed "at least annually". The framework cited includes the UDHR, ICCPR, ICESCR, "the four core labour standards of the International Labour Organization (ILO)", the UNGPs, the UN Global Compact and the OECD Guidelines.

Code of Conduct (page 204): "binding for all employees of the Lufthansa Group worldwide, regardless of their role or level", covering human rights, occupational health and safety, anti-corruption and data protection; the Group "rejects all forms of discrimination, harassment and violence".

Occupational safety policy (page 205): a globally applicable policy whose effectiveness "is monitored by the Occupational Safety Committee (OSC)"; "The Lead Safety Engineer (Vice President Occupational Safety) bears ultimate responsibility."

Processes for engaging with own workforce and workers' representatives about impacts

Reference: pages 205-206; also page 201.

Formats (page 201): the "Offen gesagt" ("frankly speaking") series with CEO Carsten Spohr; "Let's Talk" with individual Executive Board members; and "since 2025 the 'Connect!' webcast has provided a new exchange format in which the entire Lufthansa Group Executive Board engages in dialogue with employees".

Annual survey (page 205): "Since 2015, the Lufthansa Group has conducted the annual employee survey 'involve me!'" It "alternates between a full survey and a shortened version every two years", is anonymous and voluntary. "The survey was carried out again in 2025 ... The Company exceeded its target benchmark value of 3.6, reaching 3.9 in 2025 ... 0.1 points higher than in the previous year's survey."

Results go to the Executive Board and Supervisory Board and are "analysed and evaluated by management levels, functions and occupational groups". The 2024 results fed the "Cultural Journey" initiative, focused in 2025 "on the themes of feedback, psychological safety, decision-making and health" (page 206).

Human rights engagement (page 206): the Human Rights Office holds discussions with employees, representatives and network groups "CourageUp" and "BiasFighters", and meets the works council "At least once a year". "Three audits were conducted (previous year: two) in 2025", focused on North America and global procurement.

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: pages 206-207.

"The Lufthansa Group has established multiple whistleblowing channels ... Employees can raise issues ... with their immediate supervisors or designated contacts. In addition, the Lufthansa Group has set up an electronic whistleblower system and an ombudsperson. Both are also publicly accessible to internal and external whistleblowers" (page 206).

• The BKMS system "allows whistleblowers to submit reports in writing at any time, with the option to remain anonymous".
• The ombudsperson "is an independent lawyer who is not employed by the Lufthansa Group".
• Discrimination, sexual harassment, human rights violations "or breaches of environmental laws can also be reported directly to the Human Rights Office".

Handling (page 207): reports "are first checked for plausibility and then classified into categories such as criminal offences or human rights violations", then routed to the designated HR departments. "The Human Rights Officer and Internal Audit department ... conduct the review of the complaints procedure's effectiveness." Protection (page 207): "Employees who report unlawful or non-compliant behaviour, or who assist in investigations, are fully protected against any related personal disadvantage."

The S1-17 table records five complaints "submitted using the channels for own workforce" in 2025, down from ten (page 213).

Taking action on material impacts on own workforce

Reference: pages 207-209.

Measures derive from the HR strategy, are financed by the Group and "incorporated into the annual planning" (page 209).

Health and sustainable employability (pages 207-208): occupational medical care in Germany, Austria, Switzerland and Belgium; worldwide Group health management; and a nutritional traffic-light system "introduced in 2025 in Lufthansa Group staff restaurants in Germany".

Occupational safety (page 208): "a Group-wide occupational safety self-assessment survey was rolled out worldwide in 2025 ... All Group companies with at least 20 employees were included." External audits followed at companies selected on "elevated accident rates and the occurrence of serious workplace accidents". A "Group-wide minimum standard for the coordination of external contractors" was implemented in September 2025.

Pay and work-life balance (pages 208-209): "in March 2025, the second collectively agreed pay increase became financially effective for approximately 20,000 ground employees"; company-supported childcare at Frankfurt and Munich; the CareBenefit portal from January 2025; and a new part-time collective bargaining agreement for Lufthansa Airlines cabin crew.

Training (page 209): mandatory e-learning via the Learning Management System, plus the "GoAhead4LC3" female leadership and "Globalists" international talent programmes, both continued in 2025.

Targets related to own workforce

Reference: pages 209-210, table T067 "ESRS S1-5 | 46 Lufthansa Group human resources targets".

Both Group-wide targets were met: the 25% female management target set for end-2025 was exceeded at 27.6%, and the engagement index of 3.9 exceeded the 3.6 benchmark (pages 205, 210). The measure "comprises the proportion of female managers in the Group Executive Board and the three subordinate management levels" (page 210).

How targets are set (page 209): "The Lufthansa Group derives its targets from both the Group strategy and its Human Resources strategy. In Germany, the targets set are presented to the co-determination bodies, such as the Group Works Council and the Group Economic Committee ... The Group strategy department monitors these targets and reports on them to the Group Executive Board."

Coverage limitation stated (page 209): "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." No quantified targets are therefore set for health and safety, training, work-life balance or remuneration equity, and no successor target beyond 2025 is disclosed for female leadership.

Characteristics of the undertaking's employees

Reference: pages 210-211, tables T068 to T071 (headcount basis, as at 31 December 2025).

By country (T069, page 210): Germany 70,772; Switzerland 11,939; Other 20,544 - reported "According to company headquarters for each country", not country of deployment. T051 under SBM-1 gives the alternative regional split by place of deployment (page 125).

Turnover (page 210): "The total number of employees who left subsidiaries or the parent company during the reporting period was 6,532 (previous year: 6,826), and the employee turnover rate for the reporting period was 6.1% (previous year: 6.4%)."

Commentary (page 211): "In 2025, 98.2% of Lufthansa Group employees were employed on permanent contracts (previous year: 97.7%) ... the part-time employment rate stood at 35.1% (previous year: 34.6%)."

Non-guaranteed hours employees nearly doubled year on year, from 1,052 to 1,963; the report does not comment on the change. The calculation-methods table flags "Measures planned to disaggregate personnel data by country of deployment" (page 233).

Collective bargaining coverage and social dialogue

Reference: pages 211-212, table T072.

"Employees covered by collective bargaining agreements in countries in the European Economic Area (EEA) alone make up 65% (previous year: 64%) of the Lufthansa Group's total worldwide employees" (page 211).

T072 presents coverage in bands rather than percentages. Germany is the only country shown as meeting the disclosure threshold ("for EEA countries with >50 employees constituting >10% of the total workforce"), for both collective bargaining coverage and workplace representation. Non-EEA coverage is not disclosed.

Social dialogue (page 212): "The Lufthansa Group is subject to the so-called Euro Info Agreement. The agreement involves employee representatives from the various European companies and locations of the Group who are briefed by management on structural, economic and financial matters."

The related risk is reported candidly: "the collective bargaining wage agreements for ground staff at Deutsche Lufthansa AG, Lufthansa Cargo AG and Lufthansa Technik AG expired at the end of 2025, with a subsequent no-strike obligation of six weeks. This increases the risk of industrial action from mid-February 2026" (pages 202-203).

Only Switzerland (11,939 employees) and Germany (70,772) exceed 10% of the workforce on the T069 country basis, yet only Germany appears in T072; the report does not explain the difference.

Diversity metrics

Reference: page 212, tables T073 and T074 (headcount as at 31 December 2025).

Gender distribution at top management level - "Top management comprises the Group Executive Board and the three subordinate management levels":

Age distribution (T074, page 212): over 60 - 9,080 (8.8%); 55-59 - 12,772 (12.4%); 50-54 - 11,798 (11.4%); 45-49 - 13,235 (12.8%); 40-44 - 12,126 (11.7%); 35-39 - 12,733 (12.3%); 30-34 - 12,018 (11.6%); 25-29 - 11,582 (11.2%); 20-24 - 7,003 (6.8%); 18-19 - 697 (0.7%); 15-17 - 211 (0.2%).

The share of employees over 60 rose from 7.8% to 8.8% while the 18-19 band fell from 1,050 to 697, consistent with the demographic-change risk described in the HR strategy (page 203).

Recognition is noted alongside the metrics: "In 2025, Lufthansa Technik was awarded the Helga Stoedter Prize for 'Mixed Leadership' ... Following the women@LHT programme (2022-2024), the proportion of female managers at leadership levels increased significantly, from an initial 9% to over 23%" (page 210).

Health and safety metrics

Reference: page 212.

"In the 2024 financial year, the Lufthansa Group introduced an occupational safety management system that covers all companies and is based on the Group policy approved by the Group Executive Board. 100% of the Company's own workforce (previous year: 100%) is covered by a management system" (page 212).

"Across all companies, a total of 1,324 (previous year: 1,357) workplace accidents occurred that resulted in at least one calendar day of absence ... The Lufthansa Group recorded no fatalities as a result of workplace accidents in the reporting year (previous year: 1) and one fatality due to work-related illness (previous year: 1)" (page 212).

The accident rate fell by 13% year on year. A separate, differently defined figure appears in the parent-company table T047: a "Recordable work-related accident rate" of 9.7 for Deutsche Lufthansa AG (2024: 11.0) (page 109).

No number of days lost to injuries, accidents, fatalities and work-related ill health is disclosed, and no fatality figure for other workers on Group sites.

Compensation metrics (pay gap and total compensation)

Reference: pages 212-213.

Gender pay gap: 24% in favour of male employees (previous year: 27%) (page 213). "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" (page 212), "accounting for all components such as fixed and variable payments and benefits ... regardless of employee group, position, subsidiary or country. ... This is an unadjusted figure, in line with the calculation requirements of ESRS S1-16" (page 213).

Annual total remuneration ratio: 1:94 (previous year: 1:86) - "the ratio of the highest paid individual's annual total remuneration to the median annual total remuneration of all employees"; the highest paid individual "was the Chairman of the Executive Board of Deutsche Lufthansa AG" (page 213).

Company commentary (page 213): the Group attributes the gap to workforce structure and argues the figure "is of minimal relevance" - "out of around 34,000 ... flight attendants ... approximately 80% ... were female ... Among the 11,400 pilots ... 7% ... were female and 93% were male. This shows that the above figure does not necessarily indicate a lack of fairness in remuneration."

The pay gap narrowed by three percentage points while the CEO pay ratio widened from 1:86 to 1:94; the report does not comment on the ratio movement.

Incidents, complaints and severe human rights impacts

Reference: page 213, tables T075 and T076.

Incidents and complaints (T075):

Severe human rights impacts (T076):

"The Lufthansa Group's Human Rights Office received complaints from internal and/or external stakeholders across all operations on the following grounds" (page 213). Where fines are recorded as nil the Group explains the accounting treatment: "The total amount of fines, penalties and compensation payments is recognised in the income statement under other operating expenses" (page 213).

Reported discrimination incidents rose 13% year on year, from 45 to 51, while complaints through the own-workforce channels halved from 10 to 5. The report offers no commentary on either movement, and does not disclose how many of the 51 incidents were substantiated or remediated.

Policies related to value chain workers

Reference: pages 216-217.

LkSG policy statement (page 216): the risk management system "is described in the annual policy statement on the LkSG approved by the Executive Board ... [It] applies worldwide to all consolidated companies of the Lufthansa Group unless they are legally required to publish their own statement." A Human Rights Officer sits in the Human Rights and Infrastructure department "reporting directly to the Executive Board" and reports to it "every six months and on an ad hoc basis". A Group Human Rights Steering Board chaired by that officer brings together Corporate Responsibility, Compliance, Procurement, Internal Audit and Occupational Safety.

Group procurement policy (page 216): "The obligation to assume social and environmental responsibility is an element of the Group procurement policy ... The suppliers' obligations include adherence to the ten principles of the UN Global Compact, the five core labour standards of the ILO and contractual requirements under the LkSG."

Supplier Code of Conduct (page 217): applies "to all suppliers of the Lufthansa Group", addresses "environmental protection, social aspects and responsible business conduct", and "sets the minimum standards for suppliers, their employees and subcontractors". The Group "does not tolerate any unethical business conduct such as corruption, bribery, forced labour, child labour".

Processes for engaging with value chain workers about impacts

Reference: page 217.

"The Lufthansa Group follows a needs-based approach to involving workers in the value chain ... [it] takes into account the perspectives of workers in the value chain through processes such as human rights and environmental risk analyses as part of due diligence procedures and the targeted inclusion of suppliers ... The views of workers in the supply chain may also be obtained through on-site audits and supplier questionnaires as part of preventive and remedial measures. In addition, procurement officers may directly contact suppliers and their employees" (page 217).

Representatives are used as proxies: "Involving stakeholder representatives, such as works councils and trade unions, offers another way to capture the interests of workers in the value chain ... Such involvement occurs as needed and is triggered, for example, by a complaint, a detected potential impact or a rule violation."

Cross-industry forums (page 217): the Human Rights and Non-Discrimination Team and Group Procurement Team "take part in events such as the 'Peer Learning Group Human Rights' of the UN Global Compact's German network and the 'econsense Forum for Sustainable Development of German Business' several times a year".

No direct engagement with value chain workers or their own representatives is described; engagement runs through suppliers, audits and questionnaires.

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: pages 218-219.

Channels are the electronic whistleblowing system (anonymous option), the external ombudsperson, email to the Human Rights Office, or post to Deutsche Lufthansa AG; both the system and the ombudsperson "are available in several languages" (page 218). Suppliers must "inform their employees, including their own suppliers and their employees" of these channels.

Outcomes for 2025 (page 218): "In 2025, seven complaints were reported via the Lufthansa Group's complaints channel, in relation to sexual harassment (2), inappropriate working conditions (1) and unequal treatment (4). All complaints were thoroughly examined; where necessary, feedback was obtained from the relevant suppliers. One complaint relating to sexual harassment was still under review at the time of publication of this report. By the end of the reporting period, none of the complaints that had been fully examined (6) could be substantiated. Accordingly, no further remedial action was taken."

Effectiveness and protection (pages 218-219): "The effectiveness of the complaints procedure is reviewed at least once a year and on an ad hoc basis". "The Lufthansa Group follows a zero-tolerance policy regarding retaliation against whistleblowers", extending protection to non-employees.

Taking action on material impacts on value chain workers

Reference: pages 219-220.

Screening (page 219): "Before concluding contracts, suppliers are generally assessed for compliance with human rights, labour and environmental standards and integrity ... If a supplier falls within a risk category, an in-depth review will be carried out." "No changes were made to the currently implemented standards in the reporting year."

Quantified 2025 activity (page 220): "Over 200 internal and external investigations of critical suppliers and external incidents were concluded, with more than 200 further investigations initiated. Six self-assessment questionnaires were collected from business partners and, in nine cases, further information was requested ... Moreover, in 61 cases additional documents were requested from suppliers ... In addition, contracts concluded by the Lufthansa Group with 17 suppliers were reviewed ... and were revised or supplemented to include ESG criteria where necessary."

Escalation (page 220): where a violation cannot be eliminated the Group may suspend the relationship and "As a last resort ... reserves the right to terminate business relationships."

Stated gaps (pages 219-220): "Global framework agreements are yet to be concluded with international trade union federations", and "So far, the Lufthansa Group has not specifically examined direct opportunities in relation to workers in the value chain."

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 221.

No quantitative target is set, and the company says so plainly: "The Lufthansa Group did not set itself any quantitative targets for the reporting year, since it focused on the implementation and stabilisation of measures" (page 221).

What is disclosed instead is a qualitative objective: "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 ... Targets are defined on the basis of the previous risk assessment as well as complaints received via the complaints procedure."

"The overarching targets have been broken down and specified for relevant areas. These include the implementation of a risk assessment for existing suppliers using the risk assessment system, as well as continuously updating supplier questionnaires based on regulatory requirements and insights" (page 221).

Worker involvement in target-setting (page 221): "Workers in the value chain and their legitimate representatives are not currently directly involved in the process of identifying and monitoring targets. However, information regarding their situation is taken into consideration via information sources such as risk assessment data, warnings or the whistleblower system."

Policies related to consumers and end-users

Reference: pages 224-225.

Non-discrimination and health and safety (page 224): "The Lufthansa Group places great importance on valuing and including people regardless of their national or ethnic background, gender, religion, beliefs, disability, age or sexual identity ... [it] is firmly opposed to all forms of discrimination and has anchored this principle in a policy statement." Its goals "include ensuring the health and safety of its customers and guaranteeing the comprehensive protection of personal data. Both aspects are firmly embedded in the Company's Code of Conduct."

Data protection (page 224): the Group data protection policy "is designed to safeguard customers' privacy and ensure the security of their data ... [It] applies across all areas of the Lufthansa Group ... approved by the Executive Board, which is ultimately responsible for it."

Passenger safety (pages 224-225): aircraft "are secured in accordance with applicable regulations when no crew is on board". "Detailed guidelines are in place for dealing with unaccompanied minors and passengers with limited mobility. These are integrated into the Company's booking systems." Frameworks applied include "the Resolution Against Trafficking in Persons adopted by the International Air Transport Association (IATA)", supported by "a reporting process for flagging suspected cases of human trafficking that has been approved by the authorities".

Processes for engaging with consumers and end-users about impacts

Reference: pages 225-227.

Passenger Airlines (page 226): "a 'Passenger Satisfaction Tracking' (PST) programme is also in place. It receives over 30,000 customer responses each month." Customers who consent "receive a request for feedback on their travel experience three days after their flight." A Net Promoter Score is derived through the same process, and the Chief Commercial Officer of Passenger Airlines "has the highest level of responsibility".

Co-Creation Hub (page 227): "Customers are involved in product development processes through surveys, workshops and interviews ... All interested parties have access to this platform, and non-customers are likewise able to participate."

Corporate customers (page 227): Lufthansa Technik calculates its NPS "twice a year by contacting selected customers using a criteria-based approach"; Lufthansa Cargo surveys quarterly and runs a biennial survey "focusing on service quality, customer satisfaction, improvement suggestions, efficiency and complaints management".

Environmental communication (page 227): "the Lufthansa Group sales team conducted numerous interviews and surveys during the reporting year to assess desire among corporate customers to reduce CO2 emissions ... willingness to pay to reduce CO2 emissions was higher in Europe than in other regions." Corporate customers "receive a monthly report detailing their CO2 emission savings".

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: pages 228-229.

Central complaints procedure (page 228): "Anyone can report human rights or environmental impacts or violations by the Lufthansa Group or its direct suppliers. Whistleblowers may also include Lufthansa Group customers."

Product and service complaints (page 228): "Customers receive a ticket number, which Lufthansa Group employees use to process the complaint ... The Lufthansa Group regularly reviews the effectiveness and accessibility of consumer channels." Accessibility measures include "multilingual notification channels, digitally and by telephone" and an anonymous option. "The type, number and processing status of incoming complaints are subject to structured monitoring in order to evaluate the system's effectiveness."

Segment channels (pages 228-229): Lufthansa Cargo "customers with repeated compliance violations are flagged accordingly and excluded from further business activities". Lufthansa Technik applies "Just Culture" - "all reports - including anonymous ones - are treated confidentially and are used solely to improve safety performance". Lufthansa Aviation Training uses the IQSMS system, splitting "General Reports" from "Flight Safety Related Reports", reviewed monthly.

No number of consumer complaints received in 2025 is disclosed.

Taking action on material impacts on consumers and end-users

Reference: pages 229-232.

Risk management (pages 229-230): "Where trade-offs between mitigating negative impacts and business pressure need to be made, consumer wellbeing and compliance with legal requirements take precedence."

Actions in the reporting year (page 231): annual mandatory web-based GDPR and customer-data training for all employees, with "A monitoring system ... to ensure full participation"; first aid training for cabin crew and the "Doctor on Board" programme running since 2006.

Sustainable travel options (pages 231-232): "For European connections, the Lufthansa Group's Green Fares comprise 20% SAF and 80% climate change mitigation projects ... Since December 2024, Green Fares have also been available on intercontinental connections and comprise 10% SAF and 90% climate change mitigation projects." Uptake was "around 5% (previous year: 4%) of tickets".

Litigation disclosed (page 232): "Deutsche Umwelthilfe (DUH) brought a lawsuit against Deutsche Lufthansa AG in the reporting year, alleging that its advertising was misleading ... DUH was successful before the court of first instance, Cologne Regional Court ... Deutsche Lufthansa AG has lodged an appeal." A VZBV case against Eurowings was dismissed at first instance; "VZBV then lodged an appeal which was partially upheld", and Eurowings "adjusted the wording in question on its website".

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 233.

No targets are set, and the company states so explicitly. "The Lufthansa Group did not set any specific targets regarding its material impacts, risks and opportunities in the reporting year" (page 233).

The disclosure goes further and states that no target-setting or effectiveness-review process exists for this topic: "Moreover, there are currently no processes in place for target-setting or reviewing the effectiveness of policies and measures in relation to material impacts, risks and opportunities associated with consumers and end-users" (page 233).

The reason given is a reliance on existing standards rather than measured outcomes: "The Company aims to ensure customer safety and security, service quality and appropriate product information. Due to its established standards and internal guidelines, it does not see a need for additional quantitative targets" (page 233).

This sits alongside metrics the Group tracks but does not target - the Net Promoter Score and the Passenger Satisfaction Tracking programme with "over 30,000 customer responses each month" (page 226), and the share of tickets sold with a more sustainable flying option, "around 5% (previous year: 4%)" (page 232).

Business conduct policies and corporate culture

Reference: pages 238-243.

Code of Conduct (page 238): it "provides the framework for acting with integrity and responsibility, within which all business decisions must be made" and is "binding for all employees of the Lufthansa Group worldwide, regardless of their role or hierarchy level". Its contents draw on "the UNGC, the UN Guiding Principles on Business and Human Rights (UNGPs), the Core Labor Standards of the ILO, the OECD Guidelines ... and the IATA resolution against human trafficking", covering "anti-corruption, handling of conflicts of interest, fair competition, foreign trade regulations, anti-money laundering [and] insider information".

Compliance guidelines (page 239): "The Group Compliance Guideline regulates the structure of the Lufthansa Group's Compliance Management System based on the widely recognised IDW PS980 standard." "The Group Integrity Guideline contains provisions for the prevention of corruption and bribery ... [and] defines clear rules for the handling of invitations and gifts."

Whistleblower protection (page 239): "The identity of whistleblowers is treated as strictly confidential ... The Company has a zero-tolerance policy towards any form of reprisal."

Further policies described are the Competition Compliance, Anti-Money Laundering, Security, Resilience and Safety Guidelines, the Security and Safety Management Systems and Group-wide data protection (pages 239-243).

Management of relationships with suppliers

Reference: pages 243-244.

"The Lufthansa Group places great importance on ensuring that its suppliers comply in full with the relevant laws, guidelines and regulations on fair competition, integrity and responsible business practices ... [it] seeks to fulfil its due diligence requirements and to avoid entering into business relationships with persons or companies that do not meet these standards" (page 243).

Risk management (page 243): "The aim of the Lufthansa Group's risk management system for procurement processes is to identify human rights, environmental and compliance risks or violations of Group standards in the supply chain and to prevent, minimise or, if necessary, terminate them ... If the risk management system identifies such a risk in relation to a supplier, appropriate measures are initiated."

Tendering (page 244): "The Lufthansa Group systematically integrates human rights and environmental requirements in its tender procedures ... [they] are included in the specifications ... and are also incorporated in the evaluation matrix which serves as a basis for the selection of suitable suppliers." The Supplier Code of Conduct "formulates the Lufthansa Group's expectations regarding social, environmental and ethical responsibility".

No supplier numbers, screening coverage or audit counts are given under G1-2; the quantified activity sits under S2-4 (page 220).

Prevention and detection of corruption and bribery

Reference: pages 244-245.

Compliance Management System (page 244): it "follows the audit standard IDW PS 980 and consists of seven pillars: compliance culture, compliance objectives, identification of compliance risks, compliance programme, compliance organisation, compliance communication and compliance monitoring", with modules for "Integrity (Anti-Corruption), Capital Market Compliance, Competition Compliance, Embargo and Export Compliance, External Workforce Compliance and Anti-Money Laundering".

Annual risk assessment (page 244): "Once a year, the compliance managers of all Lufthansa Group companies with operational activities must assess their exposure to relevant compliance risks ... The results ... are reported to the Executive Board, the Audit Committee and the Supervisory Board."

Investigation independence (page 244): investigations are run by the Corporate Compliance Office and Corporate Security and reported to committees that "are independent of the management chain involved in the matter".

Training coverage (page 245): web-based trainings "are repeated every two years" and "all management levels are required to participate in anti-corruption and web-based compliance training". "Based on available personnel master data, 100% (previous year: 100%) of risk-prone functions are covered by at least one training format."

Targets related to business conduct

Back-filled from the business conduct chapter, where targets fall under the MDR-T/GDR-T disclosures rather than a numbered DR. G1-3 became a standalone DR only in the 2025/2026 ESRS.

No outcome-oriented business conduct target is stated. The ESRS content index lists G1-1 to G1-6 with no targets row (page 154), and no dated business-conduct target appears in the chapter.

Consistent with MDR-T, effectiveness is tracked in the absence of a target:

• Coverage metric held at ceiling - "Based on available personnel master data, 100% (previous year: 100%) of risk-prone functions are covered by at least one training format" (page 245).
• Annual compliance risk assessment - "Once a year, the compliance managers of all Lufthansa Group companies with operational activities must assess their exposure to relevant compliance risks ... From this, recommendations are derived to mitigate identified risks through specific actions" (page 244).
• Periodic reporting - quarterly to the Group Compliance Committee and annually to the Supervisory Board (page 245); "Internal Audit and an external auditor review the entire Compliance Management System" (page 240).
• One quantified control target, in payment practices - "timely payment ... is a control indicator with a target of 92%, based on the number of incoming invoices" (page 249).

Incidents of corruption or bribery

Reference: page 245; calculation method page 250.

"In 2025, there were zero convictions (previous year: zero) and EUR 0 (previous year: EUR 0) in fines imposed on the Lufthansa Group for violations of anti-corruption or anti-bribery regulations" (page 245).

Consequences where a violation is confirmed (page 245): "The Lufthansa Group does not tolerate any violations of its anti-corruption and anti-bribery regulations. If an investigation should confirm a violation of applicable anti-corruption or anti-bribery regulations, the Lufthansa Group will take appropriate individual actions, taking into account the individual circumstances of each case. This may consist of disciplinary action, claims for damages, increased training and awareness activities, extraordinary internal audits, improvements to the standards concerned and processes to prevent future violations."

Data basis (page 250): "Data collection by the Lufthansa Compliance department, based on convictions and fines imposed on Lufthansa Group companies", with "Low uncertainty" and an accuracy level of "High". No external validation is recorded for this datapoint.

The disclosure covers convictions and fines only. The number of confirmed incidents of corruption or bribery, the number of incidents involving own workers dismissed or disciplined, and any incidents relating to contracts with business partners are not separately quantified.

Political influence and lobbying activities

Reference: pages 245-249, tables T078 and T079.

Representatives (T078, pages 245-246): the Group names every individual active in lobbying, by company - Deutsche Lufthansa AG (including CEO Carsten Spohr), Lufthansa Cargo AG, Lufthansa Technik AG, Eurowings, Austrian Airlines and Brussels Airlines.

Financial contributions (T079, page 246), EUR thousands:

Lobbying topics (pages 247-249): more than 35 positions are listed, updated quarterly in the German Bundestag lobby register. They include "Financing of SAF quota through uniform levy", "Expansion of free SAF certificates", "Application of Carbon Border Adjustment Mechanism (CBAM) in aviation", "No introduction of a kerosene tax", "Reform of the Green Deal ... so as to establish competitive neutrality", "Transposition of EU Corporate Sustainability Reporting Directive (CSRD) unchanged into German law", and "Reforming strike law".

Revolving door (page 249): four named individuals "held a comparable position in public administration, including regulatory authorities, in the two years prior to their appointment". Registers are listed for the EU, Germany and Austria.

Payment practices

Reference: page 249, table T080; calculation method page 250.

"The Lufthansa Group's standard payment deadlines are 30, 60 and 90 days. Generally, there is no further categorisation of suppliers regarding payment terms at the Lufthansa Group. The average payment period at the Lufthansa Group is 51 days (previous year: 41 days)" (page 249).

Payments complying with standard terms (T080, page 249):

"Other payments are made on the basis of individual contract terms and are settled by the Lufthansa Group accordingly, so these are not covered by the table."

Legal proceedings (page 249): "The current number of pending legal proceedings for late payment is two (previous year: zero) for the year 2025 at the Lufthansa Group."

Control (page 249): "timely payment (on the basis of the payment deadlines applied) is a control indicator with a target of 92%, based on the number of incoming invoices." Payment outflows are monitored "Group-wide through system reports on a monthly basis", with results discussed with business units several times a year.

The average payment period lengthened by ten days year on year, from 41 to 51 days, and pending late-payment proceedings rose from zero to two. The report offers no commentary on either movement.