Guideline regarding Invitations, Gifts and other Benefits and Sponsorship Contracts
When accepting and granting invitations, gifts, donations and other benefits (hereinafter referred to as “benefits”), as well as concluding sponsorship agreements, special caution must be exercised.

Benefits should be limited in value and occur in a form so as not to be construed as a ’pay-off’, ’kickback’ or ’bribery’. Even low-value benefits, e. g. in connection with expectation of a return service, may be considered impermissible or even illegal.

Even the appearance of impropriety should be avoided. It is helpful to ask yourself the following question: Would public disclosure of the facts embarrass or tarnish the image or reputation of the involved persons and / or the company?

When accepting or granting benefits please take into account the respective national fiscal regulations concerning the receipt of non-cash benefits. Even if a gift is in line with the respective applicable fiscal laws, it may still violate the principles laid down in these guideline and therefore be impermissible.

Benefits which will be granted or accepted in accordance with local customs or traditions, should also be considered socially acceptable and adequate.

Business practices and customs may vary from country to country and should therefore be taken into consideration before any decision is made with regard to an exception. Please also keep in mind, that even in such cases, no binding dependence arises and the domestic and foreign statutory regulations must be complied with.

For your own protection please make sure that the highest degree of transparency is ensured. Confidential benefits, as well as multiple benefits over a short time frame may be illegal. Corruption

often begins with lesser benefits whose frequency and value increases over time and leads to binding dependence. If you find yourself in a questionable situation the process should be documented and your superior notified immediately.

Department-specific special rules should be complied with (e. g. general purchasing guideline).

When dealing with government authorities or agencies, please also pay strict attention to their special rules or guidelines. It is therefore recommended that you explicitly ask the government authority or agency about the existence of any such rules or guidelines.

The following should be taken into consideration when granting donations: Donations should not be tied to any countervailing obligations. Donations in excess of USD 5,000 require the approval of the Deutsche Lufthansa Executive Board.

The conclusion of sponsorship contracts is permissible if they serve the purpose of advertising of public relations. There should be no imbalance with regard to the financial expenditure involved and the service that is expected in return. The sponsorship concept should be documented. Any existing department-specific regulations concerning sponsorship should be complied with.

Violations of these rules may result in labor, criminal and/or civil consequences for you.

If you have any questions on how to deal with benefits or sponsorship contracts, please contact your superior first. Furthermore you may contact the Compliance Office or the Compliance Appointees of the respective legal departments as follows: