Introduction

Respect for human rights is self-evident and forms an integral part of the corporate culture of Lufthansa Group1 as a group

of companies that acts with responsibility and integrity. Retail inMotion Limited (“RiM”) a wholly owned subsidiary of LSG

Lufthansa Service Holding AG, itself a wholly owned subsidiary of the Lufthansa Group.

 

Modern slavery is a crime and a violation of fundamental human rights. We are committed to improving our practices to

combat modern slavery and human trafficking. Our statement outlines the steps we have taken to prevent Modern Slavery

within our Group and our supply chains and sets out our plans for future improvements.

 

This statement is made pursuant to section 54 (1) of the United Kingdom’s Modern Slavery Act 2015 and constitutes RiM’s

slavery and human trafficking statement for the financial year ending 31.12.2018. Ireland has similar legislation, primarily

the Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act

2013 with which RiM also complies.

 

Organisational structure

The Lufthansa Group is an aviation group with worldwide operations and 135,534 employees and more than 550

subsidiaries and affiliated companies as of 31.12.2018.

 

The portfolio of Lufthansa Group comprises the Network Airlines, the Eurowings Group and Aviation Services. The business

segment Network Airlines comprises the companies Lufthansa, SWISS and Austrian Airlines. They offer their customers a

premium product and, thanks to the multi-hub strategy, a comprehensive route network combined with the highest degree

of travel flexibility. The business segment Eurowings Group comprises the flight operations of the Eurowings Group as well

as Brussels Airlines and the equity investment in SunExpress. They offer an innovative and competitive product for pricesensitive

and service-oriented customers in the growing direct-traffic segment. Lufthansa Group carries over 142 million

passengers each year with currently 763 aircraft flying to 343 destinations in 103 countries.

 

The Aviation Services are leaders in their worldwide markets and strengthen the portfolio of the Lufthansa Group. They

include the business segments Logistics, MRO (Maintenance, Repair and Overhaul), Catering (“LSG

Lufthansa Service Holding AG”) as well as other companies and Group functions. Further information regarding the

Lufthansa Group’s structure may be found at:

https://www.lufthansagroup.com/en/responsibility/sustainability-reports.html


1. Lufthansa Group means Deutsche Lufthansa AG, and its related bodies corporate, as defined in Section 18 of the German Stock Corporation Act (Aktiengesetz).

 

Policies

As a participant of the UN Global Compact since 2002, the Lufthansa Group attaches great importance to conducting its

business in line with internationally acknowledged principles and is committed to embedding respect for human rights as an

integral element of its corporate culture. The Group has a large unionised workforce represented by a number of different

trade unions. Our Group Companies consult with employee representative bodies, including trade unions and works

councils2.

 

The binding Code of Conduct documents the values, principles and standards of conduct of the Lufthansa Group. Point 6

expressly states: “We respect and uphold the dignity of our employees, customers, and business partners. In all our actions,

we ensure that we act in accordance with human rights, the principles of the UN Global Compact, and recognise international

labour and social standards. In particular, we reject child labour, forced labour, and exploitation or discrimination of any

kind.” The Code of Conduct is binding for all bodies, managers and employees of the Lufthansa Group.

 

The companies are obliged to identify human rights risks and report the type and number of suspicious incidents. Individual

complaints can also be made by third parties to the external ombudsman – confidentially if so desired. Employees of the

Lufthansa Group can also report to their manager, human resources department or the employee representatives. A works

agreement with regard to grievance procedures is in place for all the Group’s employees in Germany; RiM also has its own

grievance procedures for its employees in Ireland.

 

Human Rights Working Group

A Human Rights Working Group was established within the Human Resources and Legal Affairs Division of the Executive

Board in 2017 and comprises of representatives from all relevant head office functions as well as Group companies that are

potentially at risk. The Project Group monitors and discusses any potential high and extreme risk areas, incidents and

actions in relation to Human Rights with the specific field of modern slavery. The Working Group meets at least twice a year

to monitor the Group’s progress in tackling slavery.

 

Based on an analysis carried out by Verisk Maplecroft, an advisory company, an overview of all Group companies operating

in high-risk and extreme-risk countries was drawn up, i.e. countries where the risk of human rights violations is particularly

high. The country overview is regularly updated, and regular meetings serve to communicate information and develop a

uniform, Group-wide position and strategy. Managers and Human Resources departments at these companies should be

made aware of their duty of care to avoid human rights violations and the realisation of risks due to modern slavery. From

this year onwards, a specific annex will successively be added to the employment contracts with these managers. In addition,

awareness is created by means of focused intranet communications to all the employees in the Group. This includes a

statement by the

 

Executive Board member for Corporate Human Resources and Legal Affairs, emphasising the responsibility of the Lufthansa

Group as a global company that respects human rights.

 

RiM has procedures in place governing employment practices. Our recruitment processes conform with Irish employment

law, including document checks to ensure candidates are legally allowed to work in Ireland/ the EU, contracts of employment, and measures to ensure all employees are above the minimum working age (16). Pay and reward

is linked to market rates for the relevant roles and is reviewed and benchmarked annually.


2. RiM does not have trade unions or works councils.

 

IATA Resolution on Human Trafficking

In the reporting year, the Lufthansa Group also signed the Resolution against Trafficking in Persons from the International

Air Transport Association (IATA). It supports this industry initiative, in particular by making operational staff, cabin crew and

ground staff at the stations aware of the issue of human trafficking.

 

Our Supply Chains

The Lufthansa Group has more than 40,000 suppliers. The annual procurement volume is about 18 billion euros. To meet

the standards, it sets for sustainability of its own products, the Lufthansa Group relies on close co-operation with suppliers

who share and implement these standards. This approach is also part of the Lufthansa Group’s Code of Conduct. The

Lufthansa Group expects from its suppliers that they fully comply with current law, guidelines and regulations concerning

fair competition, integrity and responsible practices.

 

The Group procurement policy includes the obligation to assume social and ecological responsibility. It is to be understood

as an overriding specification for all procurement guidelines at the Group companies. In addition, it serves as a handbook

for buyers and all employees with contacts in the procurement markets. Among other considerations, it requires that these

obligations be included in contracts with suppliers to:

    • comply with the ten principles of the UN Global Compact;
    • comply with the four basic principles of the International Labour Organisation (ILO);
    • consent to announced and unannounced audits by companies of the Lufthansa Group;
    • accept the termination of the contract in the event that these contractual obligations are breached.

 

By imposing these obligations, the Lufthansa Group endeavours to ensure responsible practices by its direct suppliers and

therefore meets its own standards for corporate responsibility.

 

Further Steps to Prevent Modern Slavery

The Lufthansa Group as a globally operating group of companies, sees it as its responsibility to make a contribution.

Companies do not control political developments in countries they operate in, however, they have a responsibility in the

sphere of their work, especially towards their employees worldwide. In the coming year, the Group will look to further improve

its structures, practices and trainings to combat Modern Slavery and Human Trafficking.

 

Approval for this statement

This statement was approved by RiM’s board of directors with respect to the Financial Year 2018.


Stefan Patermann, Director

Retail inMotion Limited

13 June 2019