Deutsche Lufthansa AG

The Group Policy Committee (GPC) was also established. It is chaired by the Chief Executive Officer. The GPC discusses politically significant issues, also relevant to sustainability, and prepares decisions. Individual managers within the committees are responsible for implementing concrete activities and projects. [...] The Lufthansa Group actively participates in relevant national and international business and industry associations and their environmental and sustainability working groups. They include active memberships of the International Air Transport Association (IATA), Airlines for Europe (A4E), Federal Association of the German Aviation Industry (BDL), Federal Association of German Industry (BDI), German Equities Institute (DAI) and econsense. A4E, for example, has a Jour Fixe every fortnight, during which position papers on environmentally relevant issues are drafted and consultations on draft legislation are actively supported. The Lufthansa Group also maintains a direct exchange with national ministries and EU bodies through the associations."
"###### RESPONSIBLE POLITICAL ENGAGEMENT

Concept

**Lufthansa Group strives for responsible**
**political engagement**
The Lufthansa Group also strives to voice its legitimate interests at the political level and to discuss them with representatives of the various national and international authorities and institutions, and to provide specific information on concrete issues. Depending on the occasion and the topic, this is done at the Company or Group level or in consultation with other companies or interest groups.

The Group's political engagement focuses on transport (market access and traffic rights), climate policy and fair competition. Positions are also formulated on developments at the regional and local level that are relevant to the Lufthansa Group, and shared with the responsible authorities. Recommendations for action are frequently put forward in close cooperation with the industry associations IATA, A4E and BDL as well as other bodies such as the BDI, BDA and the Forum Nachhaltige Entwicklung der Deutschen Wirtschaft e. V. (econsense).

###### Organisational foundations and responsibilities

The central department Corporate International Relations and Government Affairs, which reports directly to the Chief Executive Officer, is responsible for representing the political interests of the Lufthansa Group. It has offices in Berlin, Frankfurt and Brussels as well as liaison offices in Washington, Moscow and Beijing. In addition, the principal foreign companies of the Lufthansa Group coordinate their own responsibilities for national political issues with the central department.

###### Targets

**Lufthansa Group aims to safeguard its interests**
The Lufthansa Group seeks to identify political developments that are relevant for the Group and its subsidiaries at an early stage, to formulate positions and to introduce recommendations for action into the political decision-making process. The aim is to safeguard the interests of the Lufthansa Group in national and international regulations to protect its competitiveness and economic viability.

###### Measures

**Focus on regular exchange and transparency**
Lufthansa Group employees who work in the Corporate International Relations and Government Affairs department maintain frequent dialogue with ministries and members of parliament at the state and federal level as well as with representatives of the various EU institutions. This includes supplying facts and figures and working through the issues, some of which are complex. The Lufthansa Group also contributes to legislative processes to protect the Company's interests.

The Lufthansa Group attaches great importance to transparency in its political engagement, and it has been reported in the EU Transparency Register since 2008 under the number 0714344663-32. The Lufthansa Group regularly publishes its position on current political issues and upcoming decisions in its Policy Brief, which is addressed to political decision-makers but is also accessible to the general public. Six issues of the Policy Brief were published in the reporting year and are available on the Company's website.

##### Organisational foundations and responsibilities

The Corporate International Relations and Government Affairs department, which reports directly to the Chair of the Executive Board, is responsible for representing the political interests of the Lufthansa Group. It has offices in Berlin, Brussels and Frankfurt for representation in relation to the European Union and the German government, along with further liaison offices in Washington, Moscow (currently closed), Singapore and Beijing. In addition, a sub-department is responsible for air traffic rights at Deutsche Lufthansa AG. Some foreign subsidiaries of the Lufthansa Group are themselves responsible for national political issues and air traffic rights matters.

##### Measures

###### Focus is on regular dialogue and transparency

Employees who work in the Corporate International Relations and Government Affairs department maintain a regular dialogue with ministries and members of parliament at the state and federal levels as well as with representatives of the various EU institutions. This includes supplying facts and figures and working through issues, some of which are complex. Furthermore, the Lufthansa Group actively contributes to legislative processes to protect the Company's interests, such as in relation to the European Commission's Fit for 55 legislative package.

The Lufthansa Group attaches great importance to transparency in its political engagement, and is listed in the EU Transparency Register under the number 0714344663-32. Moreover, the Company features in the lobbying register of the German Bundestag (lower house of parliament) under the registration number R001474. The Lufthansa Group regularly publishes its position on current political issues and upcoming decisions in its Policy Brief (which is addressed to political decision makers but also accessible to the general public). In the reporting year, explanations were provided on topics relating to the harmonisation of the European airspace (the "Single European Sky"), the new Lufthansa Group fares for more sustainable flying and the prerequisites for the potential expansion of SAF via a "book and claim" system.

The Group Policy Committee (GPC), chaired by the Chairman of the Executive Board, discusses politically significant issues, including those relevant to sustainability, and prepares decisions. Individual managers within the committees are responsible for implementing concrete activities and projects. [...] The Head of the Corporate Responsibility department – who reports directly to the Chief Sustainability Officer - is responsible for assessing climate-related risks and opportunities as well as overseeing the climate protection strategy. The Corporate Responsibility department is developing appropriate measures, while working closely with the various departments and business units of the Lufthansa Group. To address the growing importance of carbon accounting, and environmental legislation, and to provide relevant information on regulations and interpretations to the affected departments and employees, the Corporate Responsibility and Group Controlling departments have established the Emissions Management Committee. This committee regularly discusses current developments in national and supranational emissions legislation and estimates their financial impacts.

The Supervisory Board also oversees and guides employee incentives. Emission reduction targets are an element of long-term variable remuneration for the Executive Board of Deutsche Lufthansa AG further described in METRICS AND TARGETS C. [...] **Group Policy Committee** The Group Policy Committee (GPC), chaired by the Chairman of the Executive Board, discusses politically significant issues, including those relevant to sustainability, and prepares Lufthansa Group's strategy for mitigating policy risk. Individual managers within the committees are responsible for implementing planned activities and projects. [...] Each identified climate risk has a risk owner within Lufthansa Group. Each owner is responsible for ensuring that the given risk is continuously monitored and assessed, and that measures are introduced in good time to help mitigate this risk. For example, the Head of Corporate International Relations and Government Affairs has been delegated climate-related risks resulting from regulatory aspects, and the risk owner of identified flight related physical climate risks and opportunities is the central flight operations department. Climate-related risks are identified, assessed, and monitored within Lufthansa Group's Risk Management System which is coordinated by the Risk Management department as described in RISK MANAGEMENT B. The risk assessment is conducted quarterly. The top risks are reported to the Executive Board on a quarterly basis and discussed annually in the Audit Committee of the Supervisory Board. [...] To tackle the increasing significance of carbon accounting and environmental legislation, the Corporate Responsibility and Group Controlling departments have formed the Emissions Management Committee to deliver regulatory information and interpretations to relevant departments and employees. This committee regularly discusses current developments in national and supranational emissions legislation and estimates their financial impacts. [...] Furthermore, the Sustainability Circle, led by the Corporate Responsibility department, promotes a Group-wide dialogue on sustainability topics. The members of this circle are the Corporate Responsibility Officers of the Group companies and relevant Group functions. The Sustainability Circle holds monthly meetings with an objective to promote a Group-wide exchange on sustainability topics, this also includes climate-related strategies, risks, and opportunities. [...] In 2023, the Corporate Responsibility department proactively initiated the formation of the SAF Circle – an interdisciplinary, cross-company committee. This committee convenes bi-weekly, serving as a round table for bringing together all relevant stakeholders in the SAF domain. Its primary objective is to comprehensively tackle a diverse array of SAF-related matters, ranging from sourcing, sales, and certification of emissions reduction to policy. By adopting a holistic approach that extends beyond CO2 emissions, the SAF Circle aims to address the broader climate impact of aviation.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]The processes at LHG to manage the multiple activities around climate change across business untits (BU´s) and geographies to ensure that LHG has a common approach that is consistent with LHG´s strategy on climate change, is as follows:
At Lufthansa Group the Executive Board has ultimate oversight of climate-related issues and has been responsible for reviewing LHG's climate related risks and opportunities, strategy, measures and target setting. At the Executive Board level, the Chief Customer Officer (CCO) takes over the responsibility for the company's environmental, climate and social effects. The definition of priorities and the further development of sustainability-relevant activities within the Lufthansa Group took place during the reporting year in the context of the Group Executive Board's meetings, as well as in the Group Executive Committee (GEC). The GEC, which is chaired by the Chief Executive Officer, is a senior management level entity and consists of the Executive Board of Deutsche Lufthansa AG, the CEOs of the segment parent companies, the senior executives of the Network Airlines and the heads of the Group's Strategy, Controlling and Communications departments.
The Corporate Responsibility (CR) department is responsible for developing appropriate measures to manage the multiple activities around climate change across business units, also to ensure that a common approach upon LHG´s strategy on climate change were followed. The CR department is working closely with the various departments and business units of the LHG. In addition, the LHG Sustainability Circle, led by the CR department, was established within the reporting year. Its objective of this monthly meeting is to promote a Group-wide exchange on sustainability topics, which also include climate-related topics and engagements. The members of this circle are the Corporate Responsibility Officers of the Group companies and relevant Group Functions.
To address the growing importance of carbon accounting and environmental legislation and to provide relevant information such as regulations and interpretations to the potentially affected divisions and employees, the Corporate Responsibility and Group Controlling divisions have also established the Emissions Management Committee. This committee regularly discusses current developments in national and supranational emissions legislation and estimates their financial impacts.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes