With the SWISS compliance programme, which is based on the Lufthansa Group’s compliance programme, the company and employees should be protected from violating the law and at the same time, supported in applying the law correctly. The compliance programme is comprised of the elements of Competition, Capital Market, Integrity and Embargo Compliance. Using an ombudsman system, there is the possibility to report suspicions based on illegal economic trading or violations against compliance regulations.

The compliance programme is in continuous development and includes, among others, detailed compliance guidelines, training (eLearning and classroom training) and a compliance organisation which is made up of the employees responsible for compliance and a SWISS compliance committee. Furthermore, regular reports regarding compliance themes and case studies are presented to the executive bodies of SWISS and Lufthansa.

The Code of Conduct and its contents form the basis for our daily business activities as well as dealings with shareholders, colleagues, customers, suppliers, business partners and other interested parties. The Code of Conduct is designed to cover the different areas of our business and our business activities as fully as possible. It should serve as a guide for us in ethically or legally critical situations which we may be confronted with in our international workplace. The adherence to these regulations helps to ensure and improve the safety, quality and sustainability of our business and its activities.

SWISS is reliant upon potential violations of law being reported immediately. Only this way can misunderstandings be remedied immediately and damages (e.g. claims for damages, criminal and anti-trust proceedings, loss of reputation) can be avoided effectively.

Especially if employees, business partners or customers have a specific suspicion that due to the behaviour of SWISS:

• economic crimes such as corruption, fraud or breach of trust;
• violations against competition or anti-trust laws;
• insider trading or market manipulation

are taking place, they should contact the SWISS Compliance Counsel immediately or the external ombudsman Dr Rainer Buchert about it.

The ombudsman is an independent, practising lawyer, who is not employed by SWISS. As a neutral, independent point of contact, he accepts tips via the phone or in writing and forwards these, if the person notifying so desires, and only anonymously, to the SWISS Compliance Counsel for further investigation.

Please also be aware: The ombudsman does not take any tasks from customer service. Therefore, he does not handle any complaints about flight and luggage irregularities or any bookings. Nor does he forward these on.

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 Lufthansa Group Corporate Compliance Office.