Compliance Management System (CMS) at Airfoil Services Sdn Bhd (“ASSB”)

Compliance describes all measures taken to ensure the correct conduct of companies, their management and staff with respect to statutory and the Company’s own obligations and prohibitions. ASSB is adopting the Lufthansa Group Compliance requirements, which is intended to prevent staff and the Company from coming into conflict with the law and at the same time to help them to apply statutory regulations correctly. ASSB’s Code of Conduct is aligned with Lufthansa Group’s Code of Conduct (Link), which includes our policies regarding conduct toward competitors, a commitment to combatting corruption and respect for human rights, as well as international labour and social standards. ASSB’s Compliance Management System (“CMS”) serves as a structured framework designed to ensure the Company operates in accordance with applicable laws, regulations, and ethical standards. Our CMS comprises a set of policies, processes, and controls that guide how we manage our compliance obligations, covering key elements such as data protection, integrity and anti-bribery, antitrust, trade compliance and anti-money laundering. ASSB Compliance function serves as the first point of contact for all compliance-related matters within the organization. It is established to ensure that employees have access to guidance, support, and advice when faced with questions or concerns regarding legal and regulatory requirements, ethical conduct, or compliance policies. ASSB Compliance has direct reporting to Lufthansa Group Corporate Compliance Office (“GCO”) which is chaired by Lufthansa Chief Compliance Officer (CCO) and reporting to the Lufthansa Executive Board, the Lufthansa Supervisory Board and its Audit Committee.

Guideline regarding Invitations, Gifts, Donations and Sponsorship

Integrity is not just a formality, but a crucial prerequisite for gaining and maintaining the trust of our customers, business partners and government institutions in the long term. At ASSB, we act transparently and responsibly and prevent any appearance of undue influence in our business transactions. Caution is exercised when accepting and granting invitations, gifts, donations and other benefits, as well as donations and sponsorship which must be consulted with ASSB Compliance at all times.

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.

ASSB has established a set of internal policies to guide our employees in managing invitations, gift, donations, sponsorships and declaration for conflict of interest.