Code of Conduct for Lobbyists of Austrian Airlines pursuant to § 7 Lobbying Act

As at: June 2017

Target Group

Subject to this Code of Conduct are all management bodies, employees as well as other agents or representatives of Austrian Airlines (hereinafter also referred to as “Lobbyists”), while performing activities that are subject to the Austrian Lobbying and Advocacy Transparency Law LobbyG, BGBl. I No. 64/2012.

Austrian Airlines incorporates Austrian Airlines AG as well as all subsidiaries where Austrian Airlines AG directly or indirectly holds a minimum of 50 % of the shares or where it is entitled to exercise decision-making voting rights.

All lobbying activities must be performed in accordance with the applicable laws, in particular the Lobbying Act as well as all intercompany rules. This Code of Conduct applies to all lobbying activities performed in the interest of Austrian Airlines.

Principles for the performance of lobbying activities

Democratic decision-making processes require the involvement of stakeholders and interested parties in conveying their specific interests to the public sector.

The activities of the Austrian Airlines Lobbyists focus on informing, presenting arguments and promoting Austrian Airline’s position as well as the professional procurance and representation of corresponding interests. All lobbying activities must be performed in an equitable manner in accordance with the applicable laws as well as intercompany rules and regulations.

The transparent and professional lobbying of Austrian Airlines for that matter supports well-informed decisions by contributing in-depth knowledge and expertise to decision makers while observing the following principles:

1. Professionalism

All lobbying activities must be performed in a fair and professional manner. High ethical and moral behaviour must be displayed on the day and any improper behaviour is to be avoided.

2. Regulatory compliance

The performance of lobbying activities must be in compliance with the law, in particular the Lobbying Act and intercompany rules and regulations of Austrian Airlines.

3. Integrity

In performing lobbying activities, it is forbidden to gather information in an improper manner, or to even attempt doing so.

Any kind of improper or inappropriate behaviour or any exertion of pressure on officials is prohibited. Socially acceptable and legally sound actions are permitted in order to promote an intervention.

4. Prohibition of acts of corruption or other improper behaviour

The granting or promising of illegal advantages to officials is strictly prohibited. Participation in activities that give the slightest impression of being improper, corrupt or illegal is to be refrained from. The Austrian Airlines Integrity Compliance Guidelines as amended are to be followed at all times.

5. Respect

Interaction with officials and colleagues must occur in a respectful manner, observing the natural form of courtesy and with due regard for their professional and personal reputation. Racist, sexist, religious or any other form of discrimination is to be avoided at all cost.

6. Honesty

The Lobbyists must present information about their lobbying activities, the principal they represent and their specific interests in a transparent and comprehensive manner. In performing lobbying activities, officials and other interested parties must be given true, current and correct information at all times.

The Lobbyists must always refrain from making possibly misleading presentations of facts.

7. Integrity/Confidentiality

The performance of lobbying activities must be carried out with the appropriate integrity. All information meriting confidence obtained through lobbying activities on behalf of Austrian Airlines is to be kept confidential. It must be neither divulged nor used for any other purpose. The obligation of confidentiality can be waived either with the express consent of Austrian Airlines or based on a legal obligation to disclose.

8. Conflict of interests

Any actions which expose officials to a conflict of interest are to be avoided. This is especially the case when there is reason to believe that the official could be or will be influenced by an act in his impartial administration.

Lobbyists of Austrian Airlines must always keep themselves informed on relevant, publicly available restrictions on activities and rules on incompatibility concerning the officials, and act accordingly.