Combined Management Report

Anti-corruption and bribery matters and respect for human rights

Anti-corruption and bribery matters

Objective Conduct in compliance with laws and regulations has highest priority at Fraport. Fraport does not tolerate any form of corruption or other unfair business practices. In addition, Fraport is committed to internationally recognized standards, guidelines, and principles, in particular the principles of the UN Global Compact, the Universal Declaration of Human Rights, and the Core Labour Standards of the International Labour Organization, as well as the OECD Guidelines for Multinational Enterprises.

Concepts, measures, and results Within the scope of its management responsibilities, the Executive Board determines the values and codes of conduct of the Fraport Group and draws up the framework conditions for the legally compliant and ethical behavior of its executives and employees. Combating corruption is a key component of the fully revised Fraport Code of Conduct, which was rolled out globally in 2022. The Executive Board is expressly committed to the fundamental values set out in the Code of Conduct and takes a clear stand with a “zero tolerance principle”.

The Group-wide Compliance Management System (CMS) contains various measures for combating corruption for which Group-wide minimum standards apply. The minimum requirements require the Group companies to have comprehensive regulations for the handling of gifts and invitations, conflicts of interest, and the compliance audit of business partners. In addition, uniform specifications for the processing of information about compliance violations are provided. The responsibility for the CMS of each respective Group company lies with its local management. In the role of Chief Compliance Officer, the head of the “Legal Affairs and Compliance” central unit is responsible for the content, organization, upkeep, and further development of the CMS of Fraport AG. This officer reports directly to the Executive Director of Retail and Real Estate.

The CMS of Fraport AG is based on and starts with a compliance risk analysis, which is carried out regularly – most recently in 2022 – and whose main areas of focus include the fight against corruption. With its Compliance Helpdesk, the Compliance department of Fraport AG supports and advises employees of all positions and hierarchy levels.

The Compliance department of Fraport AG informs the Executive Board in a semi-annual report on the status of the anti-corruption measures. The Executive Board receives information on material compliance violations immediately after they become known.

The Compliance Board of Fraport AG supports and promotes the cooperation between the Compliance Management (CMS), Risk Management (RMS), Internal Control System (ICS), and audit subsystems. It is the central body that brings together topics specific to the departments and interfaces, and further develops the CMS on an ongoing basis.

Guidelines on receiving invitations and gifts have been defined for the employees of Fraport AG in a separate policy. This regulates, among other things, the electronic documentation of the approval of received gifts and invitations. An internal policy on how to deal with conflicts of interest also exists. The employees of Fraport AG are obliged to report any situations, in which they find themselves, where personal interests could contradict Fraport’s business interests. This allows reportable facts to be disclosed electronically, and the required measures to then be initiated. The electronic processes support employees in complying with existing laws and internal regulations.

Examining adherence to the Fraport Group’s compliance regulations falls under the remit of Internal Auditing. This department provides independent and objective audit and consulting services in all major business units of Fraport AG, its subsidiaries and joint ventures, and Group companies and carries out compliance audits. A standardized and risk-oriented planning process is the foundation for the focus points of the audit.

Measures to combat corruption, along with information and instructions on how individual employees can contribute to this, are regularly communicated to the employees of the Fraport Group. Employees must complete training on anti-corruption matters. The e-learning program on important compliance fundamentals was fully revised for Fraport AG employees in 2022. In addition to a clear presentation of why compliance is important in everyday working life, the new Fraport Code of Conduct, dealing with gifts and invitations, and conflicts of interest are central elements of the new online training. In addition, the central reporting channels for compliance violations are detailed.

A key instrument for preventing and discovering compliance violations is the whistleblower system (see Employees, business partners and customers can anonymously submit information about irregularities in all Group companies via this online system. It is available 24 hours a day worldwide. The factual content of each report is thoroughly reviewed, and sanctions are initiated, if necessary. Furthermore, Fraport AG has an ombudswoman, an external, independent lawyer, at its disposal. Employees at the Frankfurt site can also contact an internal representative.

A risk-based compliance due diligence conducted by the “Acquisitions and Investments” strategic business unit is in place to examine the integrity of Fraport AG business partners’ activities in foreign-related investment projects – material compliance risks of a potential business partner are considered accordingly as part of a standard process.

The Group companies implement their own targeted measures to combat corruption and bribery based on the Group-wide CMS requirements. In fiscal year 2022, the Group companies focused on the final implementation of the Group-wide minimum requirements for the local CMS, which were revised in 2021.

Performance indicator – No performance indicator, target value, or term has been defined within the scope of the Sustainability Program.

Respect for human rights

Objective – Fraport aims to comply with the international codes of conduct that it endorses. These are especially the principles of the UN Global Compact, the Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises, and the Core Labour Standards of the International Labour Organization (ILO).

Concepts, measures, and results – The “Corporate Development, Environment, and Sustainability” central unit of Fraport AG deals with, among other things, coordinating Group-wide respect of human rights. Employees can anonymously report violations via the whistleblower system that is freely accessible worldwide via In the context of implementing the due diligence obligations from the LKSG, the electronic whistleblower system was expanded by the categories “Human Rights Violations and Environmental Crimes” as of January 1, 2023. In addition, employees in Germany can contact an external ombudswoman contracted by Fraport AG or their internal representative, as needed.

Respect for human rights is anchored in the Group-wide binding Fraport Code of Conduct for Employees: Fraport undertakes to respect the fundamental right to freedom of association and the right to collective bargaining that governs the general working conditions within the Group.

As an international company, Fraport encourages diversity in its workforce and pursues the objective of rejecting any form of discrimination. Fraport undertakes not to distinguish, exclude, or favor people based on their ethnic, national and social origin, skin color, gender, age, religion, or belief system. Fraport also prohibits any discrimination based on political activity, membership in a union organization, disability, or sexual orientation. The principle of mutual appreciation and respect is an essential part of the Fraport value culture: Fraport stands for fair, respectful, and cooperative relationships.

Fraport has the same expectations regarding respect for human rights towards its business partners -these requirements are set out in the Supplier Code of Conduct. In this code, Fraport business partners are obliged to work toward ensuring that all other companies, such as subcontractors, involved in the provision of services, consistently comply with these standards.

The Group companies implement their own specific measures to ensure respect for human rights. Regarding this topic also, in fiscal year 2022, the Group companies focused on the final implementation of the Group-wide minimum requirements for the local CMS, which were revised in 2021.

Performance indicators – No performance indicator, target value, or term has been defined within the scope of the Sustainability Program.