At AirPlus International, we have a responsibility to our customers, shareholders, communities and to each other, holding ourselves to the highest ethical standards, which is reflected within the Lufthansa Group Code of Conduct, also applicable to AirPlus.

AirPlus encourages all employees and external Whistleblowers to report any suspected misconduct and compliance violations involving AirPlus’ business and provides protective measures to enable individuals to make a disclosure of such conduct or violation without fear of reprisal.

Staff members are encouraged to speak up through a variety of available channels, which are provided in our Intranet together with comprehensive information on how to raise concerns and suspicions.

Additionally, if you, as an external party, have reasonable grounds to suspect that our employees or individuals acting on behalf of AirPlus are committing compliance violations such as:

• Human rights violations (child labour, forced labor or modern slavery, unequal opportunities, disregard of occupational health and safety obligations, violations of freedom of association, withholding of an adequate wage, etc.)
• Violations of environmental obligations
• Economic crimes (corruption, fraud, embezzlement, money-laundering, etc.)
• Infringements of competition, anti-trust and state aid laws
• Insider trading or market manipulation
• Conflicts of interest
• Embargo or export control breaches
• Data protection and information security breaches,

please use our whistleblowing channels below. Your information can help to identify risks at an early stage and avert sanctions and damage to our reputation.

Information on human rights risks, human rights violations or the violation of environment-related risks will be handled by the Lufthansa Group in accordance with the provisions of the Lufthansa Group’s Rules of Procedure pursuant to Section 8 of the German Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz).

You are not obliged to identify yourself when making a report. All information received will be treated confidentially and sensitively, in adherence to the provisions of the Regulation (EU) 2016/679 (General Data Protection Regulation) and applicable national data protection laws.

AirPlus protects the identity of the Whistleblowers as well as persons who are the subject of a report and other persons mentioned in a report to the full extent of applicable laws. If you have provided a contact option (for example, by setting up an anonymous postbox in the electronic whistleblowing system), you will receive a confirmation of receipt. Follow-up questions which may arise in course of the investigation of a report will be addressed via the same channel. You will then be informed of the progress in the processing of your report and of the outcome of the investigation.

Electronic Whistleblowing System

With the help of our electronic whistleblowing system you can easily, safely and if you wish anonymously report an incident. The system enables you to send encrypted and secure messages to the Corporate Compliance Office. It operates 24/7 and is available in 11 languages:

Access to the system

Ombudsperson

The ombudsperson is a freelance attorney who is not an employee of AirPlus. As a neutral and independent contact, the ombudsperson will take your complaints in writing or by telephone. If you wish, the ombudsperson will forward your report anonymously to the Corporate Compliance Office.

Contact Form

Dr. Rainer Buchert
Buchert Jacob Partner Attorneys at Law
Tel.: +49 69 710 33 33 0
Tel.: +49 6105 92 13 55
Fax: +49 69 710 34 44 4
kanzlei(at)dr-buchert.de
www.dr-buchert.de/en/ombudsman/

Address:
Kaiserstrasse 22
60311 Frankfurt am Main
Germany

To contact our ombudsman from Germany or many other countries please dial the toll-free number: +800 5757 6868

E-mail
humanrights@dlh.de

Postal address
Deutsche Lufthansa Aktiengesellschaft
Human Rights and Discrimination Prevention, FRA CG/H
Lufthansa Aviation Center
Airportring
60546 Frankfurt / Main
Germany

External reporting channels of the authorities

Whistleblowers can also directly contact the external reporting channels (for example, in Germany, the Federal Government at the Federal Office of Justice, the Federal Financial Supervisory Authority and the Federal Cartel Office as well as additional external reporting channels on regional level, if any). AirPlus cannot assume any responsibility or guarantee any protective measures in this respect.