Statement of Lufthansa Technik AERO Alzey Management Board
As a globally active leading company in the Maintenance, Repair and Overhaul industry (MRO) operating in various business fields and as part of the Lufthansa Group, Lufthansa Technik AERO Alzey shares substantial responsibility for lawful behavior and fair competition in the relevant markets. Our goal is sustainable economic success. Compliance with applicable laws forms the basis for all conduct of Lufthansa Technik AERO Alzey employees.
The Lufthansa Compliance Programme provides a binding framework for all Lufthansa employees, therefore also for Lufthansa Technik AERO Alzey employees, and represents the clear and unmistakable commitment of the Management Board to comply with all applicable national and international laws, regulations and guidelines. We are aware that any violation of applicable laws pose an extraordinary risk to Lufthansa Technik AERO Alzey, to Lufthansa Technik, to the Lufthansa Group as a whole and to every one of us as an individual and is therefore unacceptable.
All Lufthansa Technik AERO Alzey employees all called upon to actively participate in implementing the Lufthansa Compliance Programme in their daily work and in their respective areas of responsibility, in order to prevent any harm from any individual and from our company.
Mark Johnson and Tobias Baumgart
Lufthansa Compliance Guidelines
The Lufthansa Technik AERO Alzey Compliance Program currently consists of the components Integrity, Competition and Embargo Compliance and is applied in the whole Lufthansa Technik Group. While Integrity Compliance refers to economic criminal law, the Competition Compliance Guideline ensures the observance of antitrust and competition laws and regulations. The aim of embargo compliance is to ensure adherence to sanction regulations in foreign trade and international air transportation.
The Integrity Compliance Guidelines establish general principles for anti-corruption measures and provides a framework for employees of Lufthansa Technik AERO Alzey regarding the acceptance and granting of benefits, invitations and gifts.
An invitation to events is a special form of a benefit and therefore is regulated in a separate Event Management Guideline. The Event Management Guideline provides a framework for employees of Lufthansa Technik AERO Alzey for invitations of third parties to events, either organized by Lufthansa Technik AERO Alzey or to external events. The Event Management Guideline is complemented by a checklist that must be filled in and archived by employees of Lufthansa Technik AERO Alzey prior to addressing any invitation to an event to a third party.
The Guideline Gifts, Invitation to Meals and other Benefits gives guidance to Lufthansa Technik AERO Alzey employees on provision of presents and gifts, inviting third parties to lunches and dinners and any other benefits Lufthansa Technik AERO Alzey employees wish to provide to an external party.
The Conflict of Interest Guidline provides regulations for Lufthansa Technik AERO Alzey employees, which have to be followed when they are offered any benefits, e.g. invitations to events or meals, gifts or any other benefits. Furthermore, the Guideline covers any other potential conflict of interest such as private relationships to business partners.
The Donations, Sponsorships and Memberships Guideline defines measures in order to avoid that no payments are used to influence any decisions by business partners or public officials.
The Competition Compliance Guideline familiarizes employees of Lufthansa Technik AERO Alzey with antitrust and competition laws and regulations.
In consideration of steadily increasing significance of restrictions in cross-border business activities, Lufthansa has issued an embargo compliance guideline designed to create a binding framework for our business transactions and projects.
The Ombudsman is a freelance attorney who is not an employee of the Lufthansa Group. As a neutral, independent contact, the Ombudsman takes complaints in writing or by telephone and provides them to the Corporate Compliance Office in an anonymized form, if this is what the complainant wishes. The identity of the complainant is protected by attorney-client privilege. Moreover, the Lufthansa Group has contractually agreed not to request access to any legally privileged information and to be informed of the complainants´ name only following his/her express consent.
(Last modification 10 August 2020)