Luxair ESG Report 2023

Summary

Message from our CEO

Gilles Feith Chief Executive Officer, Luxair

Dear stakeholders,

At Luxair, we maintain a firm commitment to community values. Our priorities are the safety of our passengers, the quality of our services, and the efficiency of our operations. This commitment extends beyond immediate concerns. As an essential part of European connectivity, we play a key role in uniting communities, being dedicated to promoting the positive impacts for the economy and our society. Our mission is to unite families, offering them ways to connect.

“Our strategic vision revolves around harmonizing long-term business viability with ecological and social responsibility.”

Unique to Luxair as a regional airline are our short­haul flights which not only ensure accessibility to Luxembourg but also enable links with international and financial hubs. It is especially these short­haul flights that maintain the country’s connectivity to the world.

“Short-haul flights maintain the country's connectivity to the world.”

Consequently, Luxair must carefully consider these factors, with a particular focus on ESG criteria. In a very competitive environment maintaining the best passenger airline social model in Luxembourg is challenging for Luxair. This commitment underscores our pride in connecting diverse communities, spanning from leisure travelers to professionals, and maintaining vital links between European Union hubs. In line with our commitment to sustainability, Luxair actively engages in industry discussions, notably with the International Air Transport Association (IATA), to lead the energy and technological transition. We invest strategically in our flight equipment while maintaining our social model and our environmental responsibility. Luxair advocates for eco­responsible and socially responsible consumption, condemning unsustainable flight practices. In the short and medium term, we aim to offer a more detailed label that emphasizes the local sourcing of our products. At the same time, we are constantly striving to

improve our in­flight catering service offering, phasing out single­use products in favor of an approach focused on recycled, recyclable and environmentally­friendly products for LuxairTours. Looking ahead to the medium to long term, Luxair is committed to achieving net­zero status within the aviation industry.

“I proudly affirm our commitment to promoting eco-friendly and socially responsible consumption within every facet of our operations.”

One of our priorities is to modernize our aircraft fleet. For the first time in our history, we are embarking on a comprehensive modernization process. This will enable us to take advantage of the latest aviation technologies and to significantly reduce our CO2 emissions. By taking this important step, we are strengthening our position as a quality airline in Luxembourg and the Greater Region. This marks the beginning of a journey to secure Luxair's long­term future.

“By committing to this and ordering 8 new-generation Boeing 737s and 4 Embraers, with 5 optional orders set to arrive between 2025 and 2028, Luxair has charted a course toward a sustainable future”.

These cutting­edge aircraft play a pivotal role in substantially reducing CO2 and NOx emissions, lowering fossil fuel consumption, and mitigating noise pollution. Prioritizing a modernized fleet underscores Luxair's unwavering dedication to environmental responsibility and operational efficiency.

As a regional champion, Luxair is committed to balancing the energy transition faced by the aviation sector while preserving the DNA of regional airlines in an internationally competitive environment. Continuous investments in technology, including flight planning optimization tools, showcase Luxair's commitment to optimizing its carbon footprint.

Luxair supports the Single European Sky (SES) initiative, advocating for the unification and synchronization of air

traffic management across Europe to minimize environmental impacts. The SES aims to streamline European airspace, reducing the need for longer flight paths, cutting fuel consumption, and consequently decreasing CO2 emissions. This commitment to SES underscores Luxair's dedication to sustainability, showcasing our effort to enhance efficiency and reduce the ecological footprint of aviation, aligning with our goals for a more sustainable and efficient future in air travel.

In 2023, Luxair celebrated an unprecedented achievement, transporting over 2.5 million passengers, marking a significant 22 % increase from the previous year and eclipsing our pre­pandemic passenger numbers from 2019. This historic performance not only signifies a robust recovery but also highlights the strong reception of Luxair's quality as a fullservice carrier within Luxembourg and the Greater Region. As CEO, I attribute this success to our dedicated team, whose commitment to excellence has been pivotal in achieving and surpassing our goals.

Our gratitude extends to our team for their unwavering dedication, our passengers for their continued loyalty, and all our stakeholders for their invaluable support. This collective effort is propelling us towards a future in aviation that is not only more responsible but also reflective of our shared commitment to excellence and sustainability. Together, we look forward to building on this momentum, driven by our mission to provide exceptional service and contribute positively to our community and the environment.

Gilles Feith

Key highlights 2023

2.5 M passengers

264 employees taking advantage of parental leave

10.6 years average age of the fleet

60 different nationalities

38.5 average training hours per employee in 2023

94 destinations in 2023

23 % women holding a management position

574 jobs created in 2023

7 % water consumption reduction vs 2022

4.5 % gCO2 /RTK (CO2 intensity) reduction vs 2022

323 032 t CO₂ emissions from aircraft

7 % heating fuel reduction vs 2022

1 472 MWH electricity reduced vs 2022

ABOUT THIS REPORT

The report encompasses the sustainability activities of Luxair throughout 2023, from 1 January to 31 December. It integrates historical data and insights from previous cycles for consistent and comprehensive reporting. It is crucial to clarify that this is the Sustainability Report, which is a Non­Financial Report and is distinct from the Financial Report.

The Sustainability Report thoroughly addresses the covered entities, acknowledging their critical role in the commitment to environmental and social responsibility. Transparent communication about these entities is key to demonstrating impact, fostering accountability, and engaging stakeholders in the journey towards a more sustainable future.

Luxair is committed to publish its first Sustainability Report to underpin its commitment to sustainable development. This document is essential, as it reflects our guarantee to maintaining absolute transparency on our environmental, social and governance (ESG) impacts. The rationale behind this initiative is twofold: it helps assess and communicate our progress in sustainable development, and highlights areas for improvement, thereby amplifying our corporate social responsibility.

The reporting cycle is annual. The next publication will appear in 2025, covering Luxair's sustainability achievements and performance, and Luxair's sustainability performance for 2024.

All our publications are available on our website: www.luxair.lu

Luxair is at your disposal to provide additional information on our approach to sustainable development.

Feedback and inquiries from stakeholders are welcomed. We encourage you to share your expectations and concerns at: communication.presse@luxairgroup.lu

This report was supported by the sustainability advisory firm Forethix, which provided the methodology for the materiality analysis.

REPORTING FRAMEWORK

This report has been prepared with reference to the GRI Standards 2021, an internationally recognized framework for sustainability reporting and the AA1000 Standards.

Adopting the Global Reporting Initiative (GRI) Standards for our first sustainability report significantly enhances our approach. These globally recognized standards provide a robust framework for reporting on sustainable performance, ensuring increased comparability and credibility of the reported information. By structuring our report around GRI principles, we ensure comprehensive coverage of the most relevant sustainability issues for our industry and stakeholders. This systematic and rigorous approach opens opportunities for the continuous improvement of our practices and strengthens our dialogue with stakeholders. It also allows us to identify and capture new business opportunities aligned with sustainable development principles, thus contributing to the company’s long­term resilience and competitiveness.

MATERIALITY ASSESSMENT

Guided by the principles outlined by the reporting framework, and supported by the sustainability advisory firm Forethix, Luxair undertook a comprehensive materiality assessment to identify and prioritize reporting topics based on stakeholder feedback. The concept of double materiality is predominant and mandated by European directives as well as international sustainability reporting standards and frameworks (such as GRI - Global Reporting Initiative, SASB - Sustainability Accounting Standards Board, TCFD - Task Force on Climate-Related Financial Disclosures, among others) and ESG rating organizations, which consequently affect investor considerations.

1. IDENTIFY AND DEFINE THE RELEVANT TOPICS

To develop a foundational list of critical issues within the aviation sector, an initial literature review was conducted. The aim was to identify priority topics for both impact and financial materiality.

The review covered international standards for responsible business conduct, including the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and GRI. Additionally, the analysis considered regulatory and legal frameworks (CSRD, EU Taxonomy, SFDR, CS3D), local practices, and benchmarks from peers within the aviation sector.

This thorough approach resulted in the identification of 22 CSR topics, which then underwent a detailed impact analysis to determine their relevance and significance to the aviation industry.

This section outlines the methodology Luxair employed in preparing our sustainability report with reference to the GRI Standards 2021 and the AA1000 Standards 2018. Our approach to the materiality analysis was comprehensive, incorporating perspectives from both internal and external stakeholders to ensure a holistic view of our sustainability impacts and priorities.

This assessment measured the significance of the various environmental, social and governance impacts arising from the company's activities. The process identified and prioritized important issues in the following stages:

2. ASSESS THE SEVERITY OF ESG IMPACTS

The organization's impact analysis, considering both the internal (impact materiality) and external (financial materiality) factors affecting its operations and financial viability, was methodically undertaken in a series of in-person workshops. This dual-faceted approach enabled a thorough evaluation of the organization's influence on the economy, environment, society, and human rights.

In the first phase of the workshop, the participants, including members of the CSR committee and representatives or all business units focused on impact materiality. They assessed the severity of each ESG topic's impact, from negligible to critical, and gauged the likelihood of these impacts occurring within a defined timeline.

Subsequently, the workshop progressed to rate the financial materiality. This step involved analyzing how the same ESG issues might present risks or opportunities for the company, potentially influencing future cash flows and overall company value in the short, medium, or long term. This comprehensive, structured evaluation ensured a holistic view of the organization's sustainability practices and strategic financial planning.

3. PRIORITIZE MATERIAL ISSUES

Following comprehensive inside-out and outside-in impact analyses, the results from four impact severity criteria were aggregated using a consistent averaging process (without multipliers). Each topic on the priority list was assigned scores for outside-in impact severity, inside-out impact severity, and stakeholder influence importance. Additionally, potential future priorities, termed "emerging topics," were assessed.

These scores were visualized in a dual materiality matrix, with impact materiality on the x-axis, financial materiality on the y-axis. Emerging material topics were highlighted with arrows.

The materiality matrix was presented to the CSR Committee at a specific meeting and then approved by the Executive Committee, resulting in the following matrix:

DOUBLE MATERIALITY MATRIX

Non financial topics

ENV.1 Aircraft noise

ENV.2 Greenhouse gas emissions (GHG), energy reduction

ENV.3 Sustainable aviation fuel (SAF)

ENV.4 Fuel efficiency

ENV.5 Waste management

ENV.6 Biodiversity

SOC.1 Compensation program

SOC.2 Company attractiveness

SOC.3 Health & safety at work

SOC.4 Diversity

SOC.5 Training for employees

SOC.6 Recruitment / opportunities for all

SOC.7 Customer satisfaction

SOC.8 Flight operationssafety and security

GOV.1 Human rights

GOV.2 Data protection and security

GOV.3 Sustainable procurement

GOV.4 Commitment with stakeholders

GOV.5 Business ethics

GOV.6 Innovative products

GOV.7 Transparency & communication

The criteria for identifying material topics have been set at a threshold of (4,4), determining the issues of sustainability that are considered crucial. Topics that meet or surpass this threshold, and are located in the priority area, are denoted in bold. This distinction highlights the areas that encapsulate the expectations and concerns of our stakeholders, assisting the company in navigating decisions that harmonize our business ambitions with our commitments to the community and the planet.

Moreover, disclosing performances related to these material topics is essential for transparency and accountability. It involves reporting on how the company is addressing these crucial sustainability issues, demonstrating progress, and where necessary, outlining plans for improvement. This disclosure will be specifically addressed in the section "Our Key Performance Indicator," where detailed insights into the company's efforts and achievements in relation to the identified material topics will be provided. This not only reinforces the company's commitment to its CSR strategy but also builds trust with stakeholders by providing tangible evidence of the company's efforts to contribute positively to the community and the environment.

ENV: Environmental Topics

SOC: Social Topics

GOV: Gouvernance topics

QUALITY AND ASSURANCE OF REPORTING

Compliance with international aviation standards and regulation pertinent to carbon dioxide emissions and relevant disclosures are thoroughly examined by an independent third party.

01 LUXAIR AT A GLANCE

Committed to providing a seamless customer experience throughout the entire journey

Striving for sustainability throughout its businesses while facilitating the aviation transition pathway aiming at carbon neutrality in the future

Striving for operational excellence through a modernized fleet, efficient operations, and a high level of dispatch reliability, while never compromising on safety

Continuing to prioritize customer satisfaction and expanding its range of commercial offerings to cater to a larger customer base in a changing environment

1.1 OUR ACTIVITY

Luxair's activities encompass a diverse range of aviation-related services all over Europe, North Africa and Middle East.

The airline guarantees safe travel, offering maximum flexibility to its business customers and quality travel to its leisure customers.

Luxair offers a wide range of packages and themed vacations through its tourism division. Products are tailored to a wide variety of desires and budgets, always in compliance with the strictest quality and safety standards.

As the unique airport service provider at Luxembourg airport, Luxair takes care of Passenger Assistance and all tasks relating to fast and efficient servicing of landed aircraft. Luxair’s Catering division is responsible for preparing appetizing inflight meals and loading them on-time in the best freshness conditions.

Luxair's airfreight division handles all kinds of goods with ease and efficiency. The Luxembourg Cargocenter is considered one of the largest cargo distribution centers in Europe.

Luxair: As an airline, this entity operates flights from Luxembourg to destinations in Europe, Africa and Middle East. This service is tailored mainly towards corporate clients, offering efficient travel options for business purposes. The focus is on providing reliable and comfortable airline services to meet the needs of corporate travelers.

LuxairTours this service offers full­service vacation packages and thematic holidays through its tour operating division. These packages include flights, hotel accommodations, and transfers, catering to leisure travelers. LuxairTours provides a comprehensive travel experience, emphasizing convenience and enjoyment for vacationers.

LuxairServices includes comprehensive ground handling and catering for Luxair and other airlines operating at Luxembourg Airport. Ground handling covers passenger check­in, baggage handling, and aircraft servicing. The catering aspect involves preparing and providing meals for passengers, a key factor in enhancing the in­flight experience.

LuxairCARGO has positioned Luxembourg airport as one of Europe's busiest in air freight volume. This service specializes in handling air freight for major airlines operating to and from Luxembourg. It involves managing the logistics of cargo, including loading, unloading, and storing, at the Luxembourg airport. LuxairCARGO efficiently handles diverse merchandise, including high­tech products, perishables, livestock, and consumer goods.

BOEING 737-8

Seats: 186

Speed: 853km/h

Range: 5,740 km

Average age : 5 years 4 BOEING 737-800

Seats: 186

Speed: 853km/h

Range: 4,050 km

Average age : 9.5 years 4 BOEING 737-700

Seats: 141

Speed: 853 km/h

Range: 4,600 km

Average age : 17.3 years

HAVILLAND Q400

Seats: 76

Speed: 667 km/h

Range: 1,500 km

Average age : 9.5 years

10.6 years average age of the fleet overall

Network of destinations 2023

J 96 DESTINATIONS

J 33 COUNTRIES

Dublin

Lisbon

Porto

Madrid

Funchal

Faro

Málaga

Jerez de la Fronter

Marrakech

Agadir

Tenerife

Las Palmas

Lanzarote

Fuerteventura La Palma

1.2 DRIVING SUSTAINABILITY & GOVERNANCE

As we explore the pivotal role of strategic oversight in corporate success, we turn our attention to the core of the organization – its leadership. This chapter unravels the strategic decisions made by the company's leadership, illuminating their profound impact on the path to sustainable growth and resilience.

The leadership structure is split in two:

Board of Directors

Executive Committe

The Board of Directors is composed of 11 board members, including 3 Luxair personnel representatives. It is authorized with extensive powers to take any actions not expressly stipulated against by law or the Articles of Association for the General Meeting of Shareholders. The Board sets of the Executive Committee and determines the number of members and composition of the Executive Committee and delegates to the daily management of the company to it without prejudice to any decision of areas of decision that the Board of Directors may reserve for itself.

EXECUTIVE COMMITTEE

Mr Gilles FEITH Chief Executive Officer

Mr Thomas FISCHER Chief Commercial Officer

Mr Daniel COLLING Accountable Manager

Mrs Sara MACEDO Chief Financial Officer

Mrs Emmanuelle BOURDEAU Head of Legal and General Secretary

BOARD OF DIRECTORS

Mr Giovanni GIALLOMBARDO

Chairman of the Board of Directors

Mrs Françoise THOMA

Vice­Chairman

Chief Executive Officer, Banque et Caisse d’Épargne de l’État

Mrs Angèle DA CRUZ

Member (since September 2023, replaced Jean­Louis THILL)

Ministry of Foreign Affairs, Ambassador, Director of European Affairs and International Economic Relations

Mrs Stéphanie OLINGER

Mr Tom WEISGERBER

Advisor

of Mobility and Public Works for the Department of Public Works

Mr Patrick STREFF

Mrs Doris ENGEL

Chief Financial Officer, Banque et Caisse d’Épargne de l’État

Mr Romolo BARDIN

Chief Executive Officer & Chief Financial Officer, DELFIN S.à.r.l

Mr Laurent BAUMGARTEN

Vénéré Dos Reis

MEMBERSHIP ORGANIZATIONS AND INITIATIVES

IATA: The International Air Transport Association is a trade association for the global airline industry, representing airlines from around the world.

1.3. PARTNERSHIPS AND INVOLVEMENT

Luxair actively engages in various industry associations, membership organizations, national and international advocacy groups, playing a substantial role that goes beyond routine participation, where Luxair dedicated involvement underscores its commitment to driving industry initiative and advocacy efforts.

Furthermore, Luxair acknowledges its responsibility not only towards the industry but also towards social communities, actively contributing to broader societal goals through its engagement in these influential national associations.

Our dedication is exemplified by our collaborations with organizations such as the Red Cross, Caritas or Stëmm vun der Strooss, through which we aim to help eradicate issues such as forced labor, child exploitation, and human trafficking within our sphere of influence

EASA: The European Union Aviation Safety Agency is responsible for overseeing and coordinating aviation safety.

ERA: The European Regions Airline Association is a trade association representing the interests of regional and smaller­sized airlines in Europe.

A.P.E.M.H: APEMH is a Luxembourgish association established by parents of children living with intellectual disabilities aiming to promote inclusion, advocacy, and their rights.

Croix­Rouge: The Luxembourg Red Cross is a nonprofit organization that engages in various humanitarian activities, including the provision of assistance to vulnerable individuals and communities, responding to emergencies and disasters, offering health and social services, and promoting humanitarian values and principles.

LAEC

"The Code": "The Code of Conduct for the Protection of Children from Sexual Exploitation in Travel and Tourism"is an initiative aimed at addressing and preventing the sexual exploitation of children in the context of travel and tourism.

Fedil: FEDIL acts as a multi­sectorial entrepreneurial federation, giving a voice to industrialists and entrepreneurs and encouraging economic activity in Luxembourg. Representing nearly 700 members, FEDIL is a driving force in the Luxembourg ecosystem.

Luxembourg confederation is an employers’ organization bringing together 22 federations from different sectors, including transports and travel agencies (e.g. ULAV). Their mission is to represent and support the interests of the members.

Since 2020, a profound commitment to integrate environmental management into operational activities led to the formation of the Luxembourg Airport Environmental Committee (LAEC)

SHAREHOLDERS

COMPANIES IN WHICH LUXAIR HOLDS A PARTICIPATION

State of the G-D of Luxembourg

Banque et Caisse d'Epargne de l'Etat Bil

Luxair

Luxair Finance

Others

%

S.A.

% Cargolux Airlines International S.A.

%

%

Moselle Loisirs

02 NAVIGATING THE FUTURE

2.1 MEGATRENDS SUSTAINABLE AVIATION

"Sustainable Aviation" marks a pivotal trend in the aviation industry, focusing on reducing the environmental footprint of air travel. Modernizing fleets with eco-friendlier aircraft, despite facing uncertainties and evolving regulations and initiatives include adopting Sustainable Aviation Fuel (SAF). These efforts aim to address climate change and lower carbon emissions. The challenge lies in seamlessly integrating these green technologies and navigating regulatory changes. Nonetheless, the industry's commitment to enhancing environmental performance underscores its role in fostering a sustainable future.

Sustainable aviation faces uncertainties, i.e. through climate policies impacting planning and compliance costs. Technological challenges in adopting eco-friendly solutions create scalability and economic viability uncertainties. Supply chain vulnerabilities risk disruptions, affecting sustainable fuels' availability and cost-effectiveness. Transitioning requires significant investments, posing financial challenges if green technologies' economic feasibility lags. Balancing sustainability with cost and convenience is crucial for public acceptance, and directly influences consumer behavior. Successfully navigating these risks demands proactive risk management, continuous innovation, and industry-wide collaboration.

DIGITAL TRANSFORMATION

Digital transformation reshapes aviation through IoT and AI, enhancing operational efficiency. This evolution includes predictive maintenance, leveraging data analytics for reliability. Real-time monitoring improves safety and proactive risk management. Passengers benefit from in-flight connectivity and personalized services. Efficiency gains in air traffic management reduce fuel consumption. Digital transformation fosters adaptive business models, ensuring airline competitiveness.

Embracing sustainable aviation is a strategic opportunity. It positions companies as leaders in an eco-conscious market, attracting environmentally-aware consumers. The innovation-driven approach provides a competitive edge, fostering resilience and cost-efficiency. Adoption of green technologies enhances fuel efficiency, reducing operational expenses. Positive public perception and strengthened brand image accompany the commitment to sustainability, thus cultivating loyalty.

Digital transformation in aviation poses cybersecurity threats, jeopardizing data security and requiring substantial investments in training for operational disruptions. Privacy concerns arise with extensive passenger data, demanding strict regulatory compliance. Rapid technological advancements may render systems obsolete, necessitating continuous upgrades. Effective risk management is paramount for ensuring resilience in digitalized aviation. Ongoing cybersecurity measures and regulatory compliance are essential safeguards.

Digital transformation may create some opportunities for aviation through enhanced operational efficiency via IoT and AI integration. Predictive maintenance, powered by data analytics, optimizes aircraft reliability. Real-time monitoring systems improve safety and enable proactive risk management. Passengers enjoy superior in-flight connectivity and personalized services. Efficiency gains in air traffic management result in reduced fuel consumption and environmental impact. Overall, digital transformation facilitates adaptive business models, ensuring airlines remain competitive and responsive to market dynamics.

REGULATORY CHANGES

Regulatory changes constitute a mega trend in aviation, influencing policies governing safety, security, and environmental impact. Dynamic shifts in regulations, such as emissions standards, significantly impact industry operations. Airlines must adapt strategies and investments to align with evolving legal frameworks, ensuring compliance and sustainable growth. Continuous vigilance and proactive adjustments to adhere to changing policies are key for the aviation sector.

Regulatory changes in aviation pose multifaceted risks. Compliance challenges can lead to legal and operational issues, impacting airlines' financial health. Swift adjustments to meet new standards entail substantial financial investments, potentially causing operational disruptions. Competitive pressures may arise due to varying compliance costs, affecting the industry's overall competitiveness. Uncertainty around future regulations makes long-term planning challenging, impacting strategic decision-making. Additionally, failure to comply carries reputational risks, potentially damaging an airline's image and customer trust. Vigilant risk management and adaptability are crucial for navigating these challenges.

GEOPOLITICS

Geopolitical factors such as international relations, trade policies, alliances, conflicts, and geopolitical shifts can shape the business environment, influence strategic decision-making, and impact the overall stability and dynamics of the world.

Regulatory changes in aviation present diverse opportunities. Innovation and efficiency improvements result from meeting new standards. Embracing regulations can position airlines as pioneers in safety, security, and environmental responsibility, fostering market leadership. Collaborative initiatives with stakeholders offer a voice in shaping regulations. Adapting to changes creates opportunities for new services and diversified revenue streams. Investment in sustainable practices aligns with eco-conscious travel trends. Compliance with international regulations facilitates global expansion. Airlines must strategize and commit to continuous improvement to effectively leverage these opportunities.

Geopolitical events such as the conflicts in the Caucasus, the Middle East, and Eastern Europe introduce notable considerations for aviation. These include potential airspace restrictions, heightened security measures affecting operations, and fluctuations in fuel prices. Economic impacts may influence travel demand and industry stability. Concerns linked to the Israel-Hamas conflict include a potential decline in tourism and reputational risks for airlines operating in affected regions. Recognizing the interconnected nature of geopolitics underscores the importance of robust risk management, contingency planning, and collaboration with relevant authorities to navigate the challenges presented by these conflicts within the aviation industry.

2.2 OUR CONTRIBUTION TO THE SUSTAINABLE DEVELOPMENT GOALS

UN SUSTAINABLE DEVELOPMENT GOALS (SDGS)

The Sustainable Development Goals (SDGs) are a set of 17 global goals established by the United Nations to address various social, economic, and environmental challenges. For the aviation industry, 6 SDGs are particularly relevant. Luxair supports the Agenda 2030.

Target:

Target 7.3: By 2030, double the global rate of improvement in energy efficiency.

Why is it important?

Improved energy efficiency in aviation leads to reduced fuel consumption, lower operating costs, and decreased environmental impact, addressing sustainability concerns. This goal aligns with efforts to mitigate climate change and promotes the industry's long­term viability through technological advancements and operational improvements.

Target:

Target 8.3: Promote development­oriented policies that support productive activities, decent job creation, entrepreneurship, creativity and innovation, and encourage the formalization and growth of micro­, small­ and mediumsized enterprises, including through access to financial services.

Why is it

important?

The aviation industry is a significant contributor to global employment and economic development. Adhering to SDG 8 ensures inclusive and fair employment practices, supporting a skilled workforce and fostering a socially responsible business environment. Aligning with these goals is essential for the long­term success and sustainability of aviation companies.

NAVIGATING THE FUTURE

Target:

Target 9.1: Develop quality, reliable, sustainable, and resilient infrastructure, including regional and transborder infrastructure, to support economic development and human well­being, with a focus on affordable and equitable access for all.

Why is it important?

Emphasizing affordability and equitable access, this enhances global connectivity, fostering economic and social development through the aviation industry. The goal encourages innovation and technological advancements, crucial for reducing environmental impact and improving overall efficiency. By promoting investments in resilient infrastructure, SDG9 enhances the aviation industry's ability to withstand disruptions and contributes to broader sustainable development objectives

Target:

Target 12.6: Encourage companies, especially large and transnational companies, to adopt sustainable practices and to integrate sustainability information into their reporting cycle.

Why is it important?

By optimizing fuel usage and minimizing waste, companies contribute to global environmental goals. Embracing these measures not only aligns with evolving regulations but also ensures the industry's long­term resilience. Prioritizing sustainable consumption and production is essential for environmental stewardship and industry viability.

Target:

Target 13.2: Integrate climate change measures into national policies, strategies, and planning.

Target 13.3: Improve education, awareness­raising, and human and institutional capacity on climate change mitigation, adaptation, impact reduction, and early warning.

Target 13.A: Implement the commitment undertaken by developed­country parties to the United Nations Framework Convention on Climate Change to a goal of mobilizing jointly $100 billion annually by 2020 from all sources to address the needs of developing countries in the context of meaningful mitigation actions.

Why is it important?

The aviation sector is a significant contributor to greenhouse gas emissions. Aigning with SDG 13 is indespensable for mitigating its environmental impact. Implementing sustainable practices, such as fuel­efficient technologies and alternative fuel, not only supports global climate goals but also enables aviation companies adapt to evolving regulations and societal expectations.

Target:

Target 15.5: Take urgent and significant action to reduce the degradation of natural habitats, halt the loss of biodiversity, and protect and prevent the extinction of threatened species.

Target 15.9: By 2020, integrate ecosystem and biodiversity values into national and local planning, development processes, and poverty reduction strategies to promote sustainable resource management.

Why is it important?

While aviation operates in the air, airport infrastructure impacts land ecosystems. Adhering to SDG 15 promotes responsible land use planning around airports, minimizing biodiversity loss and ecological disruptions. It aligns with global sustainability commitments, showcasing the aviation industry's commitment to environmental responsibility.

2.3 STAKEHOLDER ENGAGEMENT & INCLUSIVENESS

Luxair, fully aware of the crucial need to maintain strong connections with its community, actively embeds the expectations and requirements of its stakeholders into its decision­making process. This approach is characterized by ongoing and dynamic exchanges with clients, employees, suppliers, partners, and other key groups. Furthermore, Luxair’s sustainability approach is based on continuous dialog with internal and external stakeholders with whom it interacts at various levels. The strategy for engaging stakeholders at Luxair is rooted in transparency, attentive listening, and collaborative effort. This ensures that each decision not only propels the company's economic growth but also advances the well­being of its community and the environmental sustainability.

APPROACH TO STAKEHOLDER ENGAGEMENT

Luxair follows a comprehensive methodology for identifying and engaging stakeholders, aligning with the reporting requirements. This approach adheres to the European Sustainability Reporting Standards (ESRS) mandated by the Corporate Sustainability Reporting Directive (CSRD), integrating the GRI 2021 standards and the AA1000 2018 standards. The stakeholder engagement process involves three key steps.

Firstly, the organization identifies internal and external stakeholders, encompassing those directly or indirectly impacted by the project and those with interests or influence. The CSR Committee classified 17 stakeholders from various areas such as finance, innovation, management, human resources, and communication. These stakeholders were evaluated based on specific criteria and positioned on Luxair's map. Segmentation and prioritization followed, considering dependence, influence, vulnerability, and dialogic capacity. Priority stakeholders to be engaged are the ones with the highest level of engagement.

SUSTAINABILITY STRATEGY

In the current era of a climate emergency and heightened public awareness, there is an inherent obligation for companies to prioritize sustainability and actively work towards reducing environmental impact. Luxair, aware of the profound impact it has on the environment, acknowledges the imperative of shaping a legacy that resonates with the values of the present and future generations.

In line with its commitment to energy reduction, Luxair actively participates in a voluntary agreement within Luxembourg's industrial landscape, focusing on enhancing energy efficiency. Sustainable facilities, equipment, and processes are integral components of Luxair's developmental strategy. The cargo handling division, initially committing to a 20 % reduction in emissions, achieved a remarkable

and transitioning to energy­efficient LED lighting.

Luxair's commitment to sustainability is prominently reflected in its fleet renewal strategy. Prioritizing newer, streamlined, and fuel­efficient planes, the airline maintains an average aircraft age of 10,6 years. Efforts to reduce fuel consumption and CO2 reduction are exemplified by the installation of split scimitar winglets on the remaining Boeing aircraft 737­800. Consistent upgrades to newer aircraft engines contribute to a contributed to a 4 % reduction in fuel usage in 2023 compared to 2022.Additionally, Luxair tailors its aircraft choice to fit the destinations, choosing the De Havilland Q­400 for medium­haul flights.

Key indicators encompass the measurable success of Luxair's sustainability initiatives, including the percentage reduction in emissions achieved by the cargo handling division. Metrics also track the impact of specific measures, such as the installation of (split) scimitar winglets and the adoption of newer aircraft engines, on fuel consumption and CO2 emissions.

Luxair's policy underscores a steadfast commitment to sustainability, emphasizing the importance of responsible sustainable practices throughout the value chain, focusing on its workforce and customers. The company actively engages in collaborative agreements and operational adjustments to align its policies with broader societal and environmental goals.

In this context, in 2023 Luxair participated to the first IATA World Sustainability Symposium, where Luxair endorsed the IATA CO2 Connect initiative as one of the first Airlines signing this IATA agreement. Luxair's action plan involves ongoing participation in voluntary agreements for transparency, energy efficiency, continual investment in sustainable facilities and equipment, and a meticulous approach to fleet renewal. Similarly, Luxair continues its dedication through social cooperation to promote inclusion, innovation and protection for and of communities. The company remains dedicated to identifying innovative solutions that

embracing technologies that enhance energy efficiency, Luxair remains at the forefront of sustainable practices, recognizing the significance of its actions within the broader societal context.

Luxair is committed to both social and environmental responsibilities, aiming to balance successful business operations with the welfare of society. The airline focuses on social cooperation, inclusion, and supporting the community, seeking innovative ways to be more efficient and socially responsible. By connecting communities, Luxair not only bridges geographical distances but also fosters stronger social bonds.

The airline's efforts go beyond just caring for the environment; they also emphasize working together, welcoming everyone, and safeguarding community interests, while connecting people across various regions. Luxair's strategy aligns with values important to both present and future generations.

Additionally, within a very competitive industry and challenging macroeconomic environment, Luxair puts continuous effort into maintaining its attractive social model, notably through the application of its Collective Work Agreement. Prioritizing employee safety and welfare is absolutely central to Luxair’s activity.

MAPPING OUR STRATEGIC

JOURNEY

Advancing Aviation Sustainability Through Strategic Partnerships

The aviation sector is in a state of continuous change, with strategic choices critically influencing the path towards sustainability. This year, Luxair has achieved a noteworthy milestone in its commitment to sustainable aviation practices. During the prestigious Salon International de l'Aéronautique et de l'Espace (SIAE) in Paris­Le Bourget, a part­

nership with Boeing was unveiled, signifying an important move in the strategy for modernizing its fleet. Opting for the Boeing 737­7 places Luxair as the pioneering European customer for this aircraft, strengthening a focused fleet growth strategy.

Environmental Significance

Aligned with the environmental objectives of Luxair, the Boeing 737­8 acts a symbol of innovation and commitment to sustainability. These aircraft have been developed to deliver notable fuel efficiencies and curb direct emissions, thus contributing to the goal of reaching net zero emissions by 2050. The latest version of Boeing 737 is anticipated to consume at least 15 % less fuel, emit an equally reduced volume of CO2 and produce a 40­50 % lower noise footprint per flight.

Boeing's commitment to sustainability is evident in its latest iteration of the Boeing 737, and the collaboration is a sign of shared values in environmental stewardship. The integration of these aircrafts into the existing fleet is

expected to optimize network operations, offering adaptability based on seasonality and demand, and ensuring year­round profitability and efficiency.

As Luxair moves forward, these choices reflect its dedication to supporting a more sustainable aviation industry. With a fleet of 21 aircraft and a history of quality service, the company continuously strives for excellence, aligning business strategies with stakeholder expectations and broader global goals.

Overall mission, vision and values

All aspects reflected in the ESG report are fully aligned with Luxair’s mission statement, which aims to maintain its position as the leading airline in Luxembourg and the Greater Region by focusing on safety, customer experience and quality.

Luxair will strive for operational excellence through a modernized fleet, efficient operations, and a high level of dispatch reliability, while never compromising on safety.

As a full­service airline, Luxair is committed to providing a

seamless customer experience throughout the entire journey.

Customer satisfaction and range expansion of commercial offerings will continue to be prioritized to cater to a larger customer base in a changing environment.

Luxair is committed to maintaining the best social model for an airline operating in Luxembourg and is striving for sustainability throughout its businesses while facilitating the aviation transition pathway aiming at carbon neutrality in the future.

Luxair will continue to enhance connectivity for Luxembourg and the Greater Region, by serving close to 100 destinations.

INPUT VALUE CREATION VALUE OUTPUT

Financial Capital:

Investment in new technologies and sustainable practices

Human Capital:

A skilled workforce dedicated to safety and quality customer service.

3163 employees

Social and Relationship Capital:

Strong stakeholder relationships and community engagement.

Intellectual

38,5 Average Training hours per employee

Sustainability Initiatives: Implementing eco-friendly practices to reduce environmental impact.

For Customers:

Reliable and enjoyable travel experiences that meet and exceed expectations

For Employees:

A safe, inclusive, and empowering workplace with opportunities for career advancement

For Society:

Economic growth stimulated by connectivity and responsible environmental practices Natural

For Shareholders:

Manufactured Capital: Modern, efficient fleet and state­of­the­art facilities

New maintenance hangar One of Europe's youngest fleets

Sustainable financial returns and robust growth prospects.

IMPACT

Environmental Impact:

improve environmental performance aligned with the regional and global goals for sustainable aviation

Social Impact:

Improved quality of life in communities served, supported by Luxair’s community programs.

Economic Impact:

Boosted regional economies through enhanced air connectivity and tourism

Corporate Impact:

Reinforced brand reputation as a regional airline leader and customer­centric service

2.5 STRENGTH IN NUMBERS: EMPLOYEES AND WORKFORCE INSIGHTS

Behind every successful flight, every satisfied customer, and every innovation at Luxair stands a team member, contributing their expertise and passion.

As we navigate the complex skies of the aviation industry, we are anchored by the collective strength of our dedicated employees and non­salaried workers.

Our ethos pivots around providing an environment that champions growth, inclusivity, and collaboration. We are committed to equipping our team with the resources and opportunities they need to flourish, be it through advanced training modules, mentoring programs, or platforms for open dialogue.

Embracing diversity, in all its forms, remains a cornerstone of our operations. It is more than just a commitment on paper; it's woven into the very fabric of Luxair. By bringing together individuals from myriad backgrounds, cultures, and experiences, we foster a melting pot of ideas, sparking creativity and driving us to new heights in the aviation sector.

COUNTRY OF RESIDENCE

NATIONALITIES

2.6 GOVERNANCE STRUCTURE FOR CSR ACCOUNTABILITY

The company established a dedicated CSR committee, spearheaded by the Head of ESG together with the Executive Committee, to streamline and reinforce accountability in its sustainability endeavors. The CSR committee focuses on the critical areas defined in the materiality assessment such as Flight operations safety and security, Customer satisfaction, fuel efficiency and training of employees.

This setup ensures a cohesive approach to CSR, with concerted efforts to meet the company's sustainability goals effectively within the year of its inception.

Support is provided by key roles including the ESG Project Manager and specialized CSR committee focused on critical areas such as CO2 emissions, environmental safety, cargo operations, and social­human resources. This setup ensures a cohesive approach to CSR, with concerted efforts to meet the company's sustainability goals effectively within the year of its inception.

NAVIGATING THE FUTURE

SETTING THE STANDARD FOR ETHICAL BUSINESS PRACTICES

Ethical considerations remain at the forefront of Luxair's operations and decisions. Our fundamental values, our commitment to combat corruption and our stance against any competitive malpractices are ingrained in our framework. Recent enhancements to our framework tackle evolving global challenges, from international sanctions to rigorous anti­money laundering measures In line with our overarching commitment to sustainability, we have instituted a distinct Human Rights Policy, emphasizing the alignment of our extended partners and stakeholders with our ethical principles. For a deeper dive into our commitment to ethical standards, our corporate website and sustainability report provide extensive details.

03 KEY PERFORMANCE 2023

3.1 NAVIGATING TO CARBON NEUTRALITY

Emission & Energy Efficiency

Luxair recognizes the profound significance of environmental responsibility in today's global landscape. Firmly anchored in our core values is an enduring commitment to environmental sustainability. With an eye on the horizon, we have set a strategic target to achieve net zero carbon emissions by 2050, aligning with overarching global climate objectives within the aviation sector.

Our determination to improve our environmental performance is steadfast, reflected in every dimension of our operations. To realize these aspirations, we actively engage and collaborate with affiliates who reflect our commitment to reduce our environmental impact in aviation. Through collective innovation, we endeavor to not only achieve our environmental milestones but also to significantly reduce our ecological footprint.

Management approach

Luxair prioritizes the theme of emissions and energy efficiency as a cornerstone of our commitment to environ­

mental sustainability within the aviation industry. Our proactive approach is driven by a dedication to significantly reduce our carbon footprint and optimize energy use, embodying our mission towards a greener future. This priority is embraced by Luxair's leadership and entire team, who collectively strive to exceed conventional standards and establish Luxair as a benchmark for responsible and ethical practices in aviation across the Greater Region and Europe. By placing emissions and energy efficiency at the forefront of our strategic initiatives, Luxair not only demonstrates operational excellence but also leads by example in promoting a more sustainable and responsible future in aviation, anchored by our core principles of integrity and environmental stewardship.

Luxair's objectives align with the aviation industry's aim of achieving net­zero CO2 emissions by 2050. Operational efficiency is demonstrated through fleet renewal, flight operations optimization, and the reduction of single­use plastics. The company actively invests in expanding its fleet of electric cars used in operations and plans to replace as many as possible with ground electrical vehicles in the future. The use of renewable energy sources and Guarantees of Origin (GO) certifications further underscores Luxair's commitment to reducing overall carbon emissions.

Performance indicators play a crucial role in Luxair's commitment to environmental responsibility. Monitoring and

measurement encompass electricity consumption, waste disposal, water usage, premises heating, vehicle fuel consumption, and CO2 emissions. These indicators provide tangible metrics to evaluate the success of Luxair's energy reduction measures and its overall environmental sustainability initiatives

Related Policy

Energy Policy embodies a comprehensive strategy aimed at optimizing energy use and enhancing energy efficiency within the organization. It sets forth a framework for reducing energy consumption, leveraging renewable energy sources, and minimizing the overall environmental impact. This policy underscores the commitment to incorporating cutting­edge technologies and sustainable practices in energy management. It serves as a fundamental pillar in the pursuit of sustainability goals, offering guidelines for continuous improvement, monitoring, and accountability in energy utilization.

In implementing its energy policy, Luxair is actively involved in the expansion of its fleet of electric ground service equipment and subscribes to renewable energy sources. Initiatives such as fleet renewal, flight operations optimization, and reduction of single­use plastic are tangible actions taken to achieve sustainability goals. The dedicated app for pilots serves as a practical tool to analyze and improve

flights, instilling awareness and efficiency in the operational process. The ongoing commitment to monitoring and measurement reinforces Luxair's dedication to environmental responsibility.

Luxair is one of the Luxembourg enterprises that is committed to procure green electricity to meet its demands. The term green is used to describe the electricity generated from renewable sources with the least environmental impact. Similar to the major European countries, the grid of Luxembourg is supplied with energy from a variety of sources, each of which with a distinct environmental impact, with renewables being the best available option for maintaining environmental integrity. In a corporate reporting framework, electricity is considered green when the provider can guarantee that the quantities supplied come from a traceable and verified renewable source. In Europe, digital certificates provided by the seller in co­operation with the producer and reasonable assurance from a third party are the most popular means of demonstrating that the purchased electricity is green. Luxair has selected ENOVOS as a trusted partner to obtain electricity from renewable sources, primarily hydroelectric which have been certified by ILR and validated by EECS. Energy from renewable sources is therefore regarded as emissions free, which is reflected in the scope two carbon dioxide emissions stated in this report. All emissions pertinent to the

production and maintenance of green electricity are counted in the inventory of the producer.

Luxair reaffirms its commitments to decarbonize aviation by 2050

Anticipated outcomes are grounded in historical data, regulatory adjustments, passenger numbers, and overall aviation activities. The metric used, gCO2/RTK (grams of CO2 per revenue tonne kilometer), has shown a general reduction in CO2 intensity by ­4.5 % from 2022 to 2023.

Luxair incorporates Sustainable Aviation Fuel (SAF) into its strategy, with an estimated annual introduction rate of 2 % until 2025 and 6 % in 2030. The trajectory, illustrated in the graphic, outlines Luxair's path. Calculations extend until 2028 based on current data. The dotted line, labeled "Luxair Calculation Business Plan," sets a target of a 20 % reduction compared to 2023 by 2028. The last estimate year is 2028, recognizing that further estimations may be significantly impacted by regulatory changes and other factors. This acknowledgment underscores the dynamic nature of the data, subject to changes and integrated into the ongoing action plan.

below 2 c

GCO2/RTK PER SCENARIO

-24.4 % CO2/RTK reduction from 2020 to 2023

The specifics of carbon dioxide emissions disclosures

The carbon dioxide emissions of Luxair are classified as Scope 1, 2, and 3 under the Greenhouse Gas (GHG) Protocol’s corporate reporting standards. In this report, Luxair reports direct emissions under scope 1 and indirect emissions under Scope 2.

The specifics of the carbon dioxide emissions monitoring and reporting

The carbon dioxide emissions of Luxair are monitored and reported in accordance with the regulatory requirements of the EU, UK, and Switzerland. They are in conformity with standards set forth by ICAO and in line with the corporate reporting standards of the GHG Protocol.

SCOPE 1 Carbon Dioxide Emissions

Direct emissions of carbon dioxide that occur from sources that Luxair owns and controls. This includes emissions from the aircraft engines during flight and ground operations, transport, and service vehicles (cars, buses, aircraft stairs vehicles, cargo container loaders), stationary units, and the emissions from heating all the facilities owned and controlled by Luxair such as the HQ, cargo, maintenance, and catering.

SCOPE 2 Carbon Dioxide Emissions

Indirect emissions of carbon dioxide that result from importing electricity to run facilities owned and controlled by Luxair, including the headquarters, cargo, maintenance, and catering facilities.

SCOPE 3 Carbon Dioxide Emissions

Indirect emissions of carbon dioxide that arise from the activities of the supply chain. This includes but is not limited to activities such as production of new aircraft, acquisition of spare parts for existing aircraft, corporate travels, maintenance of pilot qualifications, preparation of means for passengers, employee commutes and a variety of activities which are difficult to monitor and report.

ENERGY CONSUMPTION

GREENHOUSE GAS EMISSIONS

Scope 1 GHG emissions*

Scope 2 GHG emissions

Scope 1 & 2 GHG emissions

Purchase of electricity** t CO2e 0 0 0

Scope 3 GHG emissions***

*Calculated and reported by sustainability and finance teams in line with the GHG Protocol Corporate Standard.

**Zero Scope 2 GHG emissions as 100 % of the electricity use comes from renewable sources.

***CO2 emissions from the supply chain of Luxair have not been measured and will not be disclosed due to the complexity of the undertaking.

CARBON EMISSIONS PER REVENUE TONNES KILOMETRE

CO2 Emissions reporting & Reasonable assurance

The main source of scope one carbon dioxide emissions of Luxair is its aircraft and the combustion of JET A1 fuel that powers the engines of its aircraft for ground and flight operations. Luxair monitors these emissions in compliance with multiple regulatory frameworks and reports them to the competent authority of Luxembourg after receiving approval from an independent verification body. The independent verification provides the competent authority and any other interested party that our annual emissions report is complete and free from material misstatements. The remaining scope one emission represent a minor portion of the total.

The scope two emissions have verified by the Institut Luxembourgeois de Régulation (ILR) and the European Energy Certification System.

FUEL EFFICIENCY

In an industry where fuel accounts for a significant proportion of expenditure, more efficient fuel consumption not only reduces costs, but also minimizes CO2 emissions. This is particularly relevant in the context of the Paris Agreement commitments and the EU's 2050 carbon neutrality targets. Luxair, as the leading airline in the region, has a responsibility to adopt the industry trends and best practices, such as modernizing the fleet with more fuel-efficient aircraft, optimizing flight routes. These actions, in addition to their positive impact on the environment, reinforce the company's image as a responsible player committed to the fight against climate change, an aspect increasingly valued by consumers and business partners alike.

Management approach

As a responsible player in the aviation sector, Luxair is committed to minimize its environmental impact while fulfilling its primary mission: transporting passengers across Europe. Addressing unique challenges such as efficiently flight path and maximizing aircraft capacity is at the forefront of Luxair's priorities.

Our approach is based on a comprehensive strategy aimed at reducing our carbon footprint through targeted initiatives such as investing in a more modern and fuel­efficient fleet, optimizing the weight on board, and adopting Sustainable Aviation Fuel (SAF) as soon as they become practically available. Luxair also strives to optimize every aspect of the journey, from flight planning and waste management to fuel­efficient flying practices, ensuring that each flight is as environmentally friendly as possible.

Adhering to Cost Index protocols, the implementation of Engine­out Taxi­In procedures, limiting auxillary power unit (APU) usage while parked, employing advanced materials in painting, and deploring reduced landing flaps and other fuel­saving measures during descent and final approach.

Key indicators include the quantifiable reduction in fuel consumption and CO2 emissions achieved through continuous descent operations, reduced thrust take­off, reduced flap take­off, and the installation of split scimitar winglets. The successful transition to a paperless cockpit, evidenced by the elimination of approximately 35 kg of paper on every B737 flight, is also a notable indicator.

The action plan involves the formulation of clear guidelines for pilots on factors such as reduced landing gear, continuous descent operations, reduced thrust take­off, and reduced flap take­off. Additionally, Luxair is actively working on the installation of split scimitar winglets across its Boeing 737­800 fleet. The transition to a paperless cockpit is a key component that necessitate tasks such as hardware selection, software development, risk assessments, and comprehensive pilot training.

Aircraft Fuel consumption

The variance in JET A1 fuel consumption over the previous three years is indicative of the conditions and constrains associated with each period.

As a result of the COVID19 pandemic, 2021 was a year of low demand, marked by slow recovery, reduced operations and consequently low fuel consumption and carbon emissions.

On the other hand, 2022 was a year that saw a sudden rise in air travel demand, necessitating a rapid ramp­up of operations that brough fuel consumption and carbon emissions back to levels seen before the pandemic.

2023 is essentially a continuation of the 2022 recovery trend and it was particularly noteworthy as it was a record year for Luxair in terms of passengers transported, that resulted in a slight rise in fuel consumption and carbon emissions.

Related policy

Luxair fuel efficiency policy for in­service aircraft details our comprehensive approach to enhancing fuel efficiency, ensuring its application, monitoring, and management. It outlines strategies to reduce consumption and environmental impact, incorporating advanced technologies and sustainable practices. This policy is central to our commitment to improve fuel efficiency and achieving sustainability goals, providing a framework for measuring progress and maintaining accountability.

PARTNERSHIP FOR SUSTAINABILITY - STAKEHOLDERS

Within the confines of this report, the crucial role of strategic partnerships in fostering sustainability within the aviation operations of the company is explored. A stakeholder­centric approach is emphasized, aligning the commitment to environmental and social responsibility with collaborative initiatives aimed at achieving lasting positive impact.

In addressing prevailing environmental challenges, Luxair has established several shared objectives in close collaboration with stakeholders. Multiple ongoing projects across diverse domains, including biodiversity, wastewater management, air quality, and noise mitigation, have been initiated. These projects aim to enhance the effectiveness of each environmental conservation activity conducted by stakeholders and promote innovation in environmental preservation.

Since 2020, a profound commitment to integrate environmental management into operational activities led to the formation of the Luxembourg Airport Environmental Committee (LAEC), comprising ANA, Cargolux, and Luxair. Regular bi­monthly meetings have been conducted since its inception. Discussions within the committee revolve around current issues, including the analysis of environmental Significant Operational Risks (SOR), focusing on potential solutions to mitigate their occurrence.

EU TAXONOMY REGULATION (EU) 2020/852 DISCLOSURE

For financial year 2023 , Luxair has incorporated the reporting requirements defined in European Union Regulation 2020/852 ("EU Taxonomy Regulation"), aimed at establishing a framework promoting sustainable investment, including the delegated acts drawn up under the regulation, applicable at the reporting date. The main objective of the EU Taxonomy Regulation is to guide investors and companies in their investment decisions concerning environmentallyfriendly economic activities. It specifies the criteria for assessing whether an economic activity is considered environmentally sustainable. For the purposes of the EU Taxonomy Regulation, the following are defined as environmental objectives:

• Climate change mitigation

• Climate change adaptation

• Sustainable use and protection of water and marine resources

• Transition to a circular economy

• Pollution prevention and control

• Protection and restoration of biodiversity and ecosystems

According to the EU Taxonomy Regulation, an economic activity is considered environmentally sustainable and taxonomy-aligned if it:

• Contributes significantly to one or more of the above objectives;

• Does not significantly harm any of the other objectives;

• Is carried out in compliance with specified Minimum Safeguards.

The EU Taxonomy Regulation mandates that non­financial entities report the extent to which they engage in economic activities recognized by the Regulation as "Taxonomy­eligible or aligned." Moreover, on an annual basis, non­financial entities are required to disclose:

a) the percentage of their revenue generated from products or services linked to economic activities deemed environmentally sustainable ("Taxonomyaligned") according to the stipulated requirements; and

b) the share of their capital investments (CapEx) and operational spending (OpEx) dedicated to assets or processes involved in economic activities considered environmentally sustainable ("Taxonomy­aligned") in line with the specified requirements.

The implementation of these disclosure obligations for the aviation sector (published on the 21st of November 2023) will unfold in two phases:

1. From January 1, 2024, to December 31, 2024,

Ratio of Taxonomy­eligible economic activities within their overall turnover (revenue), capital expenditure (CapEx), and operational expenditure (OpEx), along with any pertinent qualitative details.

2. Starting January 1, 2025,

Entities are required to report the share of Taxonomy­aligned turnover (revenue), CapEx, and OpEx as specified in points a) and b) previously, accompanied by mandatory tables and pertinent qualitative data.

The information disclosed reflect the annual reporting period of the preceding calendar year relative to the disclosure date. This implies that disclosures made in 2024 should encompass data from the calendar year 2023.

Luxair's Taxonomy-eligible activities in 2024

An economic activity qualifies as Taxonomy­eligible if it is included in the delegated acts established under the EU Taxonomy Regulation, regardless of whether it fulfills any or all of the technical screening criteria specified in those delegated acts.

For Luxair, the activities eligible towards the taxonomy fall mostly under the objective "climate change mitigation". Two economic activities covered by the EU Taxonomy were identified:

• passenger and freight air transport;

• air transport ground handling operations.

Even though Luxair operates in multiple sectors, during the screening process it was concluded that only passenger transport and ground handling have been included in the taxonomic analysis. As the Tour operator and in­flight catering activities are not included in the list of eligible activities as per European taxonomy, those activities were excluded from the analysis. The ratios retained are based solely on the turnover, CapEx and Opex of the activities listed above.

DEFINITIONS OF THE RATIOS:

As per the regulation, Luxair describes the ratios of net turnover, capital expenditure ("CapEx"), and operational expenditure ("OpEx") that are linked with eligible activities within the EU Green taxonomy.

Net turnover, CapEx, and OpEx are defined according to the EU Taxonomy Regulation standards. The definition of those KPI under this regulation are sometimes different from the International Financial Reporting Standards.

Net Turnover : Total revenue from goods sold and services provided during a financial year, as determined under Luxembourg Generally Accepted Accounting Principles (LUXGAAP).

Capital expenditure : Total of investments in tangible and intangible assets during the financial year considered before depreciation, amortization and any re­measurements associated with the taxonomy­eligible activities.

Operational Expenditure : Direct non­capitalized costs including research and development, building renovation, short­term leases, maintenance and repair costs, and other costs related to the routine upkeep of tangible assets required for the proper operation of assets. Are excluded, overheads, raw materials, the cost of the employee who operates the machine, the cost of managing research and development projects, electricity, fluids or reagents required to operate property, plant and equipment.

The ratios are then the following, all Net Turnover, Capex and Opex (still according to the EU green Taxonomy definition) in denominator and in numerator those KPI but only linked towards the Eligible activities of Luxair.

Taxonomy-eligible economic activities in Luxair's Turnover, CapEx and OpEx in 2023

03 OUR KEY PERFORMANCE 2023

3.2 TAKING CARE & BEING INCLUSIVE

Health & safety: prioritizing employee safety and welfare

In the realm of Health and Safety, Luxair prioritizes the well­being of its employees, emphasizing a meticulous management approach to safeguard occupational health.

The Health and Safety Department, comprising designated workers recognized by the Minister of Labour, operates with a commitment to hazard identification, risk prevention, and the seamless interface between occupational medicine and the Business Unit/Department.

The Health and Safety Department aligns with operational business units, implementing structured actions and utilizing an occupational health and safety management system. Embracing systematic and scientific approaches like the Kinney methodology for risk assessments and the Root Cause Methodology for analyzing workplace accidents, Luxair demonstrates diligence in managing these areas effectively.

The process to identify hazards and assess occupational risks within Luxair involves comprehensive documentation of activities in operational business units. Regular reviews by the Health and Safety Department and periodic committees ensure ongoing assessment. The Kinney method, led by a designated worker, facilitates risk assessment and prioritizes improvement actions based on quantified risk importance.

Luxair fosters a proactive safety culture through regular health and safety training, encouraging employees to report dangerous situations. While there is no formal procedure documented in the Occupational Health and Safety Management System, employees have the right to halt activities posing serious threats to their health and safety, emphasizing the importance of immediate communication with supervisors.

In the aftermath of workplace accidents, Luxair employs a thorough process, documenting incidents, reviewing data by the Health and Safety Department, and conducting root cause analyses. A designated worker leads the analysis, considering technical, organizational, and behavioral factors. Each identified cause triggers defined actions, implemented upon resource allocation. The Health and Safety Committee conducts periodic reviews, focusing on evaluating the effectiveness of actions, programs, and procedures resulting from risk assessments and accident analyses during meetings with operational business units.

Engagement programs: encouraging constructive feedback and initiative

Luxair annually formulates and monitors an occupational health and safety improvement plan, overseen by Health and Safety Committees within the business units. The commitment to enhance employee safety is a core objective, and feedback channels are established to capture insights from both the field and management, ensuring continuous improvement.

While lacking a formalized process, employee feedback is effectively channeled through various avenues, including management, designated health and safety department personnel, and the safety delegate. This feedback is consistently received and formalized during Health and Safety Committee meetings with the Business Units, serving as a crucial mechanism for ongoing improvement.

The Health and Safety Department collaborates closely with business units to adapt workstations for employees facing specific risks. Regular ergonomic studies, conducted in partnership with the company's occupational health organization, ensure a proactive approach to employee well­being. An internal redeployment procedure may be activated in the event of an employee's unfitness for their role, emphasizing a commitment to addressing individual needs and challenges.

Diversity, whether linguistic or cultural, is not considered an obstacle to employee involvement. Luxair's Health and Safety Department conducts training sessions in multiple languages, including French, English, and occasionally

German, promoting inclusivity. Linguistic integration is exemplified by the translation of safety regulations into nine languages for the Cargocenter parking lot, ensuring widespread comprehension and adherence.

To communicate Health and Safety information effectively, diverse channels are in place, including email distribution, dashboards in designated areas, and video screens for dynamic and engaging delivery. These initiatives aim to provide clear and accessible information to all employees, regardless of their roles or linguistic backgrounds. Moreover, to prevent potential conflicts of interest, the Health and Safety Department operates independently of day­to­day business operations. This ensures that improvement actions are proposed objectively and without bias, reinforcing Luxair's commitment to the well­being and safety of its employees.

ENGAGEMENT PROGRAMS: ENCOURAGING CONSTRUCTIVE FEEDBACK AND INITIATIVE

The Personnel Delegation comprises permanent members, including the Safety Delegate, who is specifically dedicated to Health and Safety topics. Every 6 months, Luxair S.A. organizes a Health and Safety Committee, with attendance from the permanent delegates, representatives from the BUs, the occupational health organization, and the Health and Safety Department.

Starting this year, technical visits are arranged every 6 months, alternating with the committees. These visits include the Safety Delegate, the occupational doctor, a representative from the management of the visited workshop, and members of the Health and Safety Department.

EMPLOYEE HEALTH AND SAFETY TRAINING

Every new employee at Luxair undergoes Health and Safety training, excluding those at the headquarters. This training encompasses the overall organizational structure, protocols for handling situations like fires, accidents, or evaluations, general risks, preventive measures, and risks specific to the respective Business Unit they are assigned to. The training is subsequently refreshed every five years. This requirement applies to all new employees, including those on permanent contracts, temporary contracts, interim staff, and summer positions, as needed for the specific role.

Employee training is a key focus area, which is why the chapter on Human Capital Development further elaborates on this point.

PROMOTION OF WORKER’S HEALTH

The multi­sector occupational health organization STM (Santé au Travail Multisectoriel), provides the company with a designated occupational doctor and a backup doctor for contingencies. The doctor is available three days a week, accompanied by two nurses, and operates from a dedicated, fully­equipped office in the Cargocenter. When a blood sample is needed, a nurse administers it, and the sample is sent to Laboratoire BioNext in Leudelange, with whom a partnership has been established. The occupational doctor is responsible for conducting all recruitment examinations, periodic check­ups, consultations at the employer's or employee's request, as well as examinations for employees returning to work after an extended absence. Additionally, the occupational doctor conducts workstation studies by visiting various Business Units.

Luxair consistently provides health­focused campaigns for all employees, addressing not only their professional roles but also their overall well­being, including a blood check­up initiative and psychological support accessible via telephone and email by an occupational doctor. Campaigns were done in 2023 and will be reconducted in a timely manner.

COVERED WORKERS IN HEALTH AND SAFETY MANAGEMENT SYSTEM

The accompanying table offers a snapshot of Luxair’s workforce covered by the company’s robust Occupational Health and Safety Management System, underscoring the commitment to inclusivity by ensuring that no employees have been excluded from its comprehensive protective measures.

Workers and employees who are not employees but, whose work and/or workplace is controlled by the organization

Workers covered by a health and safety management system

COVERED WORKERS IN HEALTH AND SAFETY MANAGEMENT SYSTEM

The health and safety of all Luxair personnel is of the utmost importance, from management teams at head office to ground handling teams and airline crews. Occupational Health and Safety performance is monitored by means of commonly used indicators, updated periodically and communicated to all staff. The table below provides annual data and illustrates a few trends. Employees

The frequency rate expresses the number of accidents per million hours worked.

The serverity rate is a representation of severity in relation to the number of days lost from work.

Based on these data, it is reassuring to note that performance in terms of Occupational Health and Safety is improving significantly in terms of work­related accidents with serious consequences. Moreover, with a significant and constant increase in the number of hours worked due to the intensification of operations and the significant rise in passenger numbers, accident rates are tending to fall over the years. The collaborative work undertaken in recent years by all Luxair managers and employees, under the impetus of the Health and Safety Department, has produced highly encouraging results.

Despite an overall reduction in the number of accidents, due to the nature of the activities carried out, particularly in the freight and passenger baggage handling sectors, the low proportion of work­related accidents with serious consequences has contributed to an increase in the number of days off work, particularly in 2023, due to long periods of recovery.

Overall, 2023 was a year of recovery and consolidation for the aviation sector as a whole and for Luxair in particular, reflected in the figures by a record number of passengers and freight handled by its workforce in all its business sectors, contributing to a 4.3 % growth in hours worked.

03 OUR KEY PERFORMANCE 2023

Workers who are not employees

Non­employee workers refers to covers interim workers, freelancers, volunteers, independent contractors, contributing to Luxair's operations.

Occupational health and safety risk assessment

The risk assessment process at Luxair encompasses various steps to ensure safety and compliance across operations.

A thorough examination of noise levels on both the Cargocenter and Terminal sides of the tarmac has been carried out, considering potential consequences, and mitigation measures are implemented to appropriately address areas of heightened sound intensity. Building on studies conducted in 2019 and 2021 with our occupational organization, the evaluation pinpoints risk zones, facilitating the implementation of protective measures and mandating their use when necessary.

This risk assessment is a collaborative effort involving diverse stakeholders and activities. By establishing risk thresholds, Luxair implements appropriate measures to guarantee an efficient safety across its operations. The main objective is to transition from a corrective to a proactive approach in risk management, emphasizing incident prevention.

Three specific sectors, namely Cargocenter, Airport Services (including baggage loading and unloading), and Catering (meal preparation and loading), present more particular risk considerations. The Ground Equipment and Maintenance departments, governed by stringent standards and regulations, demonstrate a lower accident rate.

In the event of work­related accidents, Luxair has structured response mechanisms. Superficial injuries are managed by trained First Aid personnel equipped with first aid kits strategically distributed throughout the organization. Moderate injuries prompt a medical examination, and emergency services may be contacted for further evaluation. Luxair covers transportation to the hospital, and in severe cases, an ambulance is dispatched for evacuation.

The data from 2022 underscore the importance of regular meetings and communications organized by business units to assess risks comprehensively and to make efficiency actions review. The data from 2023 shows the results of high potential risk treatment made through a significant reduction of the high consequence work related injuries.

This aids in formulating a consolidated plan with the ambition to develop a strong Health and Safety Culture with meticulous monitoring of each improvement to prevent any increase in the accident rate aiming at achieving zero accidents. Specific departments, such as LuxairCARGO, set individual targets, and periodic assessments in 2023 evaluate progress and identify areas for further adjustments.

Central to effective risk management is the commitment to open communication within the corporate culture. Managers are encouraged to engage in meaningful dialogue with their teams. In 2022, this dialogue is particularly emphasized in the Cargocenter, where operational measures and roadmaps are in place to reduce accident rates. These efforts align with Luxair's commitment to continuous improvement, safety, and proactive risk mitigation.

Risk reporting

The reporting process is carried out every 1 to 3 months. The implementation of this process is crucial for monitoring and evaluating health and safety performance. A health and safety committee in place to assess both positive and negative aspects, define areas for improvement, prioritize and validate actions to be implemented.

This exercise strengthens communication while enabling management to assert its leadership in health and safety matters.

The strong commitment of the team is a notable strength of the department. Emphasis is placed on improving working conditions through three axes: technical, organizational and human factors. This involves communication efforts, cascaded down to the operational units or within the framework of committees.

3.3 GIVING BACK TO THE COMMUNITY

COMMUNITY

Luxair actively embraces the ethos of diversity, fostering a culture marked by awareness, respect, and inclusivity among employees, customers, passengers, and partners. The commitment to inclusiveness permeates every level of the organization, substantiated by a series of comprehensive initiatives focused on diversity, awareness, and well­being.

Concerted efforts underscore Luxair's dedication to creating a workplace and operational environment that actively celebrates the richness of diversity. Internally and externally, the company's actions reflect its steadfast commitment to inclusiveness as an integral aspect of its corporate values and social responsibility. Luxair actively supports vulnerable populations through different initiatives.

Luxair extends its impact beyond local initiatives, partnering with ECPAT Luxembourg, an NGO combating the commercial sexual exploitation of children. The airline actively participates in raising awareness by promoting ECPAT's child protection campaigns through diverse media channels. Luxair takes its commitment to the next level by joining "The Code," a tourism label dedicated to ensuring the protection of children.

LUXAIR GOES ORANGE

In alignment with the International Day for the Elimination of Violence against Women, Luxair actively participated in the global movement championed by the United Nations World Organization, adopting the distinctive color orange to underscore its commitment to #OrangeTheWorld. Acknowledging the universal unacceptability of violence, Luxair directed its visibility and resources toward advocating for the defense of women and girls who tragically become victims of such acts. This symbolic gesture highlights Luxair's dedication to raising awareness and taking a stand against gender-based violence, contributing to the broader global effort to create a world free from harm for women and girls.

FROM BLUE TO PINK

For numerous years, Luxair has been actively collaborating with organizations championing social causes, especially those that hold special significance for the airline, such as Femmes en détresse and Rosa Lëtzebuerg. This year, Luxair has taken a dedicated stance to raise awareness about early breast cancer detection and screening through various initiatives. In a strategic partnership with Think Pink, a prominent Luxembourg charity founded in 2009, Luxair aims to amplify its impact. As part of this commitment, Luxair is providing its employees with access to complimentary webinars on self­screening, ensuring that awareness is not only raised externally but also internally among its workforce. This collaborative effort underscores Luxair's commitment to social responsibility and health advocacy within the community it serves.

RED CROSS

Luxair proudly upholds its enduring collaboration with the Luxembourgish Red Cross, actively engaging in fundraising collections during its flights to support this humanitarian organization. In addition to this, Luxair extends valuable financial assistance to the social grocery stores, known as "Buttek," a collaborative initiative with Caritas. These stores serve as vital resources for individuals facing insecurity, offering a diverse array of 250 products, spanning food items, clothing, and maintenance products, all priced more affordably than typical high­street rates Beyond being places for essential shopping, these Buttek stores foster community interaction, providing a space for social inclusion, conversations, and meaningful connections within the community. Luxair's commitment to such initiatives underscores its dedication to social responsibility and making a positive impact on the lives of those in need.

UGLY SWEATER

Beginning of December 2023, in an effort to support the Kriibskrank Kanner Foundatioun, a local charitable organization dedicated to aiding children with cancer, Luxair has initiated the sale of “ugly” festive jumpers, with all proceeds directed towards the foundation's cause. With a history spanning over three decades, the Kriibskrank Kanner Foundatioun has been resolute in its commitment to assisting families navigating the challenges of childhood cancer. The foundation's multidisciplinary team extends comprehensive support throughout the entire journey, from the initial diagnosis through treatment and remission. Their services encompass administrative and financial assistance, psychological and social support, as well as engaging educational activities. Luxair seizes this opportunity not only to contribute to a noble cause but also to raise awareness about the invaluable work undertaken by the Kriibskrank Kanner Foundatioun in the local community.

3.4 CUSTOMER ENGAGEMENT & ADVOCACY

Safety protocols: upholding passenger trust and security

Luxair S.A. plays a pivotal role within the multi­layered aviation security system, with a commitment to developing, implementing, maintaining, and continually improving strategies and processes. The primary objective is to ensure that all aviation activities under Luxair purview occur with a balanced allocation of organizational resources, striving for the highest levels of security and compliance performance.

The company adheres to national and international standards, integrating security excellence into all operations to fortify the business and meet regulatory requirements.

While ultimate accountability rests with the General Management, Luxair recognizes the crucial role of active participation, commitment, and a sense of responsibility among employees in maintaining secure operations.

Luxair has established a safety and compliance policy, endorsed by the Accountable Manager, reflecting theorganizational commitment to safety. This policy is visibly communicated internally through posters and presentations, with regular reviews to ensure its continued relevance. As an integral part of the managements system, it is presented in the general section of this manual, establishing high­level safety and compliance objectives for a secure and compliant aviation operation.

In response to the rapid growth of the aviation industry, Luxair places utmost importance on heightened safety measures. A pivotal step in this pursuit is the adoption of a Safety Management System (SMS), which, akin to our

financial managements system, goes beyond mere regulatory compliance to strive for excellence in safety standards and practices.

The SMS at Luxair serves as a structured methodology for safety risk management, encompassing all aspects or airline activities, including flight and ground operation, as well as maintenance. While its scope is extensive, covering operational and administrative realms, its foundation lies in a robust safety policy that undergoes periodic updates, ensuring the integration of safety into the fabric of our business.

Crucially, the SMS at Luxair advocates a proactive approach, demanding vigilance from every organizational tier. Although overseen by the Safety Manager, ultimate accountability rests with the Accountable Manager, emphasizing safety as a top­tier priority.

The foundation of Luxair's SMS is built upon the harmonization of European regulations with the ICAO's SMS framework, ensuring alignment with international standards. This commitment to a safety­centric approach reflects Luxair's dedication to maintaining and enhancing safety practices.

Luxair's SMS is structured around four pillars, forming a robust action plan that guides the organization in achieving excellence in safety standards. These pillars serve as the framework for implementing safety measures and practices across all airline activities, reinforcing Luxair's commitment to safety as a fundamental aspect of its operations.

Emphasizing management's commitment, this pillar delineates responsibilities, appoints pivotal safety personnel, and ensures efficient emergency response planning.

Centered on nurturing a safetyconscious culture, it emphasizes training, education, and open communication.

no Safety PolicyandObjectives SafetyRiskManagement ecnarussAytefaS

itomorPytefaS

A proactive section, it focuses on hazard identification and the establishment of effective risk management strategies.

This component constantly monitors safety performance, addresses change management, and underscores the SMS's continuous evolution.

Luxair employs a robust and structured approach to passenger flight safety management, leveraging data analysis from regulatory and internal sources to continuously assess and enhance aviation safety. Safety strategy is embedded across the company, underpinned by clear objectives and the monitoring of specific safety performance indicators. Regular audits and annual Safety Management System (SMS) reviews are central to this approach, ensuring compliance with national and international standards and fostering a proactive safety culture. The involvement and commitment of all employees, supported by the General Management, are crucial to achieving safety excellence and maintaining passenger trust.

A comprehensive stance on safety management is adopted, encompassing reactive, proactive, and predictive strategies. Reactive safety management involves addressing issues only when they arise, with reliance on thorough investigations that delve beyond immediate causes to include contributory factors and broader safety risks. Alternatively, proactive safety management sees potential safety concerns actively sought out by gath­

ering information from diverse sources, emphasizing a pre­emptive response to minimize system failures. Furthermore, predictive safety management reinforces the importance of actively seeking information indicative of emerging safety risks, allowing anticipatory actions to be taken. By combining these three approaches, a holistic and dynamic safety management system is ensured, fostering a culture of continuous improvement and resilience within operational processes.

In the realm of aviation, it is imperative for companies to diligently assess and analyze the health and safety implication associated with their diverse range of product and service categories, ensuring a comprehensive understanding of potential impacts on both individuals and the environment.

In the pursuit of maintaining robust health and safety standards within the realm of product and service offerings, it becomes essential for aviation companies to monitor and address incidents of non­compliance, thereby fostering a culture of accountability and continuous improvement in the management of health and safety impacts.

CUSTOMER’S DATA PROTECTION

The company maintains a regularly updated personal data protection policy. Luxair implements appropriate measures to ensure the security and confidentiality of personal data, safeguarding it against unauthorized access, alteration, or damage by third parties. Further information can be found in the "INFORMATION & DATA GOVERNANCE" section on page 69 of this report.

CUSTOMER SATISFACTION:

ENSURING COMPREHENSIVE STAKEHOLDER INTERACTION

At Luxair, the joint responsibility for products and Customers is meticulously managed by the commercial teams.

To assess customer satisfaction, Luxair employs tools facilitated by the CRM reporting system. This system functions as a robust platform for measuring Customer satisfaction, utilizing a recently designed shared survey developed by CRM and marketing teams. With a monthly feedback collection of 300­400 responses the survey ensures timely insights as Customers receive it shortly after their flight. Varied survey questions address specific customer concerns, offering a comprehensive understanding of their experiences.

Luxair’s objectives in customer management involve the enhancement of overall performance, with a strong focus on punctuality as a critical factor influencing customer satisfaction. The monthly Customer Experience and Product Review Board, a routine gathering, aims to evaluate the current situation thoroughly, scrutinize Key Performance Indicators (KPIs) for performance assessment, and address specific concerns as needed.

Key Performance Indicators (KPIs) undergo rigorous scrutiny in the Monthly Customer Service Review Board. Instances related to on­time performance are discussed to illustrate key points. A comprehensive assessment of every aspect of customer experience, including catering, onboarding, and more, takes place. Action plans are developed based on this data, acknowledging that the effectiveness of these actions may vary.

Luxair’s policy revolves around customer satisfaction, with a commitment to thoroughly analyze challenges, particularly those related to on­time performance due to increased flight volume. End of 2023, the company has chosen to exclude ACMI leasing from its strategy, opting instead to reduce flighty frequency. This strategic decision ensures a sufficient number of operational aircraft, minimizing disruptions, and enhancing overall customer satisfaction.

3.5 INVESTING IN THE FUTURE

In the aviation sector, the excellence of employees plays a pivotal role in ensuring both customer satisfaction and safety standards. Well-trained and skilled personnel are the cornerstone of delivering exceptional services to passengers while concurrently upholding rigorous safety protocols. Luxair’s commitment to safety and customer experience necessitates continuous investment in the human capital development of its workforce.

Adequate training programs not only enhance the proficiency of employees but also contribute to the overall efficiency and reliability of Luxair’s operations. As employees are equipped with the necessary skills and knowledge, they become key contributors to the company’s success, fostering a culture of excellence that directly translates into heightened customer satisfaction and elevated safety standards.

Striving to excellence, Luxair has increased the total amount of hours of training.

3.6 COMMITMENT IN RESPONSIBLE GOVERNANCE

Business ethics

Integrity management: ensuring transparent business operations

At Luxair, the shared responsibility for day­to­day activities aligns with the care values of passion, care, and responsibility. These values underscore that ethical and transparent business parties are not just preferred but the sole method for conducting operations.

Luxair actively promotes high ethical standards, requiring unwavering integrity from all stakeholders, including employees at all levels, directors, officer intern, agents, contractors, subcontractors, external consultants, third­party representatives, suppliers, and business partners. The commitment to ethical conduct is ingrained in Luxair’s culture, with zero tolerance for any from of harassment. Active measures are in place to cultivate an inclusive environment for all members of the Luxair workforce.

The group’s culture reflects a commitment to human rights, demonstrated through support for specific projects seamlessly integrated into daily operations. Luxair’s initiatives underscore a deep­rooted commitment to the well­being and fair treatment of individuals emphasize that every action taken under the Luxair name contributes to a more just and responsible world.

Zero-tolerance for corruption and rigorous anti-corruption efforts

Maintaining a zero­tolerance for corruption and implementing rigorous anti­corruption measures is crucial for Luxair to uphold ethical standards, ensure legal compliance, and foster trust among stakeholders, contributing to the safety, integrity, and sustainability of our operations.

Luxair upholds a strong position against any manifestations of corruption and bribery. All individuals associated with the organization are required to comply with the rigorous anti­bribery and anti­corruption guidelines.

Recently, an initiative was undertaken to review and enhance our existing guidelines, emphasizing clarity and thorough coverage of all potential risks. The updated framework, once approved, will be released in the near future. Additionally, digital training modules and consistent communication strategies are implemented to underscore the commitment to integrity and transparency in all operational facets.

Commitment to Human Rights

Luxair’s commitment to human rights is deeply embedded in the daily operations, with a profound belief that upholding these principles contributes to a just, equitable, and inclusive world. Aligned with The Universal Declaration of Human Rights of 1948, Luxair’s Human Rights Policy spans every facet of operations, emphasizing non­discrimination, equal opportunity, freedom of association and expression, a safe workplace, eradication of child and forced labor, and robust privacy and data protection. The company actively pursues continuous improvement by regularly evaluating the effectiveness of the policies, procedures, and programs, making necessary adjustments to ensure Luxair meets and exceeds its human rights commitments.

Commitment to anti-modern slavery statement

Luxair stands firmly against all forms of modern slavery, echoing our profound commitment to responsible and ethical business practices in every region we operate. At Luxair, we are deeply committed to maintaining high ethical standards throughout our operations, with a pronounced emphasis on aligning with the Universal Declaration of Human Rights and the United Nations’ Global Compact Initiative. Our Modern Slavery Statement stands as a testament to this commitment, advocating against underage labor, child sexual exploitation, and emphasizing the importance of labor freedom.

OUR KEY PERFORMANCE 2023

COMPLIANCE AND REGULATION: COMMITMENT TO EXCELLENCE

Luxair puts great emphasis on service excellence and consistently demonstrates an unflinching commitment to regulatory compliance. One of the main goals is to establish leadership in compliance among its peers by integrating the most recent regulations, guidelines, and industry best practices into its operations.

In order to achieve this objective, Luxair has put together compliance teams with a wealth of knowledge and experience in their field of expertise. These groups employ a proactive approach to guarantee ongoing compliance and adherence to the industry best practices. With its meticulous publication reviews, participation in aviation conferences and workshops, as well as with periodic reviews for the Safety and Quality Review Board, Luxair has proven that it is committed to being at the forefront of compliance. Luxair remains at the top of the industry not only by means of awareness but also through concentrated efforts and routine confers between compliance and operational teams that ensure adherence to the most recent regulations. This strategy allows Luxair to anticipate developments and take appropriate action when necessary. Ensuring accurate execution of updates while prioritizing safety and compliance is made possible through a robust change management system. In this sense, every change is viewed as an opportunity to improve and produce the greatest outcomes. Luxair takes novel approaches into consideration when applied procedures are proved to be impractical or unrealistic. Additionally, given the need to maintain constant levels of safety, a systematic approach to finding Alternative Means of Compliance (AltMoC) is essential. The process involves identifying discrepancies and tenable alternatives that have been approved by the Competent Authorities. For certainty that Luxair passengers enjoy the same calibre of services while flying with a partner airline, our quality and compliance teams look for operators who can meet the strictest quality and reliability requirements set forth by IOSA. This is made possible by evaluating potential code­share partners or leasing agreements using thorough procedures, and by focusing on operators who have an EASA AOC. Essentially, each component of our operation is a reflection a broader goal to establish new benchmarks among regional airlines, distinguished by safety, compliance, and a relentless quest of excellence.

SUPPLIER COLLABORATION

Strategic partnerships: building mutually beneficial relations

At Luxair, the mission revolves around creating sustainable and mutually beneficial relationships that extent beyond immediate stakeholders to encompass supplier partnerships and community ties. The overarching objective is to enhance societal welfare alongside business growth through community connectivity and strategic partnerships.

Close collaboration with suppliers is key to achieving significant impacts in sustainability goals. The pursuit of sustainability and ethical practices is paramount, ensuring that every partnership aligns with Luxair’s core values. This emphasizes the importance of a well­defined mechanism for selecting and collaborating with strategic partners.

The Supplier Code of Conduct is the main foundation concerning strategic cooperations. It will be further explained on the following page.

Implementing responsible sourcing practices

In the competitive sector of air transport, responsible sourcing is indispensable. Luxair prioritizes working with suppliers who uphold the highest standards of transparency, ethical conduct, and environmental stewardship. Our extensive presence in Europe, North Africa, and the Mediterranean demands an interconnected and reliable supply chain, one that is resilient, adaptable, and committed to sustainability.

Luxair views its supply chain as an integral part of its commitment to sustainability and ethical business practices. By focusing on responsible sourcing, we ensure that our partners and suppliers share our values and meet the standards we set for ethical conduct.

OUR GUIDELINES

AND EXPECTATIONS FOR SUPPLIERS

Luxair Supplier Code of Conduct establishes the foundation for operational integrity, fostering a responsible and ethical supply chain aiming at fair and transparent business practices, and promoting sustainability.

The Supplier Code of Conduct mandates compliance with laws and regulations, encompassing environmental laws, labor laws and regulations related to fair business practices. A systematic mechanism is in place to monitor and enforce adherence to these standards.

Rigorous standards are set to prevent bribery, conflicts of interest, and corruption, reflecting Luxair's commitment to fair and transparent business practices.

The Supplier Code of Conduct firmly opposes bribery, conflicts of interest, and all forms of corrupt activities. Luxair's political stance emphasizes the importance of transparency, integrity, and ethical behavior in supplier relationships, setting the tone for responsible business practices.

Luxair places a high priority on working and employment conditions, requiring suppliers to provide a safe, healthy, and fair working environment for their employees. This includes upholding workers' rights and prohibiting exploitative practices. The Supplier Code of Conduct serves as a comprehensive action plan, outlining the expectations and standards for suppliers to meet.

The approach to responsible sourcing at Luxair is notmerely about compliance but involves proactively setting standards and expecting partners to meet, if not exceed, these.

03 OUR KEY PERFORMANCE 2023

INFORMATION & DATA GOVERNANCE

Data privacy: safeguarding stakeholder information

Luxair's commitment to protecting personal data stands amongst the foundation of its operational principles. Adhering to the highest standards of privacy, the company rigorously complies with the General Data Protection Regulation (GDPR) and Luxembourg's data protection laws. The Data Protection Policy at Luxair is a practical document, serving in accordance with its commitment to all stakeholders. It focuses on responsible Personal Data processing and provides clear information to data subjects about their rights.

Personal information is gathered through both direct engagement and reliable third­party sources, like travel agencies. This data serves various purposes, from enhancing service performance to ensuring legal compliance and shaping marketing communications based on the consent of the data subjects.

Luxair has recently refined its data governance structure, enhancing the efficiency and effectiveness of the data management and privacy protocols. The CEO oversees overall compliance, while the Data Protection Officer (DPO) maintains independence in auditing and improving data handling practices. The Executive Committee outlines the data protection strategy and ensures adequate resource allocation. Concurrently, the Data Breach Committee, collaborating with the DPO, develops strategic responses to data incidents.

The DPO, alongside the relevant stakeholders, anticipates risks and devises strategies for data breaches and requests from data subjects. Key roles from the IT Security services  are crucial in enforcing security measures. Processing Activity Owners and Department Heads are instrumental in policy implementation and prompt incident response.

Luxair's policy is an expansive document, covering all forms of Personal Data across the company's processing activities. It commits to ensure that all processing activities are conducted in line with applicable regulation. This commitment is reinforced by comprehensive documentation, including application procedures, instructions and the definition of roles and responsibilities for all stakeholders. In order to ensure a full understanding of all the governance framework renewed within the group training materials are currently being revised, ensuring the effective application of these principles.

Annual reviews by the DPO, combined with adjustments in response to regulatory changes, ensure that Luxair's data protection measures consistently reflect industry best practices. Internal stakeholders  seeking a comprehensive overview of Luxair's data management practices and implemented safeguards are encouraged to consult the detailed policy on the Luxair intranet, a testament to the company's commitment to a culture of privacy and security.

Luxair has designated a DPO to oversee the proper processing of your personal data. For any inquiries or requests regarding the handling of your personal information, you can reach out to the DPO by sending an email to data.protection@luxairgroup.lu

Following the recent refinement of Luxair's data governance structure, as detailed in the preceding section, procedures for addressing personal data breaches and data subjects’ rights requests have been updated. These enhancements align with the strengthened governance framework, focusing on efficiency and robust data protection for all stakeholders.

As part of a commitment to continuous improvement, a comprehensive gap analysis was carried out. This strategic assessment identified areas requiring improvement to existing processes. The results of this analysis are used to fine­tune Luxair's operations to further ensuring that practices are not only in strict compliance with the latest regulatory standards, including the GDPR and Luxembourg's data protection laws, but are also able to adapt to evolving stakeholder needs and rights. This proactive approach reinforces the foundations of Luxair's data protection policy and its commitment to handling data responsibly and maintaining stakeholder trust.

In response to a data breach in the year 2023, explaining the increase of complaints between 2021 and 2023, Luxair has swiftly implemented an action plan to fortify data protection measures. This initiative involves a comprehensive review and revision of all policies connected to data security, aiming to align them with the latest industry standards. Proactive steps are taken to enhance defenses, safeguard sensitive information, and maintain the trust of clients, partners, and employees.

WHISTLEBLOWING

Incorporating a whistleblowing policy and platform is a pivotal element in Luxair’s management approach as it creates a standard process to receive and treat employee’s and external stakeholders’ (customers, suppliers, etc.) concerns, with respect of one’s privacy and/or wish to remain anonymous. This measure, in compliance with the Luxembourg law on the protection of Whistleblowers, underscores the company’s commitment to transparency, accountability, and ethical conduct within the organization. The mechanism ensures a structured process for employees to report concerns, promoting early detection and the resolution of potential issues. Objectives include fostering a culture of integrity, mitigating risks, and protecting the interests of all stakeholders. Key indicators, such as the number and nature of reported concerns, have become integral metrics for assessing the effectiveness of Luxair’s whistleblowing initiatives but also to help the organization be more aware of its risks and how these can be better tackled. This policy, and the associated whistleblowing platform, embedded in our overarching commitment to responsible practices, exemplifies our dedication to upholding the highest standards of corporate governance.

04 ABOUT THE REPORT

4.1 GRI STANDARDS CONTENT INDEX

TRAINING AND EDUCATION

DIVERSITY AND EQUAL OPPORTUNITY

4.2. LIST OF ACRONYMS

CRM Customer Relationship Management

CSRD Corporate Sustainable Reporting Directive

EASA AOC European Union Aviation Safety Agency Air Operator Certificate

EFB Electronic Flight Bag

ESRS European Sustainability Reporting Standards

EU European Union

GDPR General Data Protection Regulation

GHG Greenhouse Gas

GoO Guarantee of Origin

GRI Global Reporting Initiative

IATA International Air Transport Association

ICAO International Civil Aviation Organization

IOSA IATA Operational Safety Audit

KPI Key Perforfmance Indicators

LAEC Luxembourg Airport Environmental Commitee

PoA PowerPlant

SASB Sustainability Accounting Standards Board

SMS Safety Management System

SOR Significant Operational Risks

STM Santé au Travail Multisectoriel

TCFD Task Force on Climate­Related Financial Disclosures

UNFCC United Nations Framework Convention on Climate Change

4.3. GRI ESRS CORRESPONDENCE TABLE

2-25

ESRS 2 GOV­2 Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies

ESRS MDR­P Minimum Disclosure Requirement Policies

ESRS S1­4 Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions 62, 68

ESRS S2­4 Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those action

ESRS S3­4 Taking action on material impacts on affected communities, and approaches to managing material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions

ESRS S4­4 Taking action on material impacts on consumers and end­users, and approaches to managing material risks and pursuing material opportunities related to consumers and end­users, and effectiveness of those actions 62, 68

ESRS G1­1

ESRS S1­1 Policies related to own workforce

ESRS S1­3 Processes to remediate negative impacts and channels for own workers to raise concerns

ESRS S2­1 Policies related to value chain workers

ESRS S2­2 Processes for engaging with value chain workers about impacts

ESRS S3­1 Policies related to affected communities

ESRS S3­3 Processes to remediate negative impacts and channels for affected communities to raise concerns

ESRS S4­3 Processes to remediate negative impacts and channels for consumers and end­users

ESRS S2­3 Processes to remediate negative impacts and channels for value chain workers to raise concerns

ESES S3­3 Processes to remediate negative impacts and channels for affected communities to raise concerns

ESES S4­3 Processes to remediate negative impacts and channels for consumers and end­users to raise concerns

ESRS G1­1 Corporate culture and bBusiness conduct policies and corporate culture

ESRS G1­3

ESRS

ESRS E2­4 Polution of air, water and soil

ESRS S1­17 Incidents, complaints and severe human rights impacts

ESRS G1­4 Confirmed incidents of corruption or bribery

ESRS 2 SMB­2 Interests and views of stakeholders

ESRS S1­1 Policies related to own workforce

ESRS S1­2 Processes for engaging with own workers and workers’ representatives about impacts

ESRS S2­1 Policies related to value chain workers

ESRS S2­2 Processes for engaging with value chain workers about impacts

ESRS S3­1 Policies related to affected communities

ESRS S3­2 Processes for engaging with affected communities about impacts

ESRS S4­1 Policies related to consumers and end­users

ESRS S4­2 Processes for engaging with consumers and end­users about impacts

ESRS S1­1 Policies related to own workforce

ESRS S1­2 Processes for engaging with own workers and workers’ representatives about impacts

ESRS S1­4

Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

ESRS S1­5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

ESRS S2­2 Processes for engaging with value chain workers about impacts

ESRS S2­4 Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those action

ESRS S2­5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

OCCUPATIONAL HEALTH AND SAFETY

and

S1­4

3-3 Management of material topics

ESRS S1­1 Policies related to own workforce

ESRS S1­2 Processes for engaging with own workers and workers’ representatives about impacts

ESRS S1­4 Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

ESRS S1­5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

ESRS S2­2 Processes for engaging with value chain workers about impacts

ESRS S2­4 Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those action

ESRS S2­5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities 404-1

ESRS S1­1 Policies related to own workforce

ESRS S1­2 Processes for engaging with own workers and workers’ representatives about impacts

ESRS S1­4 Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

3-3 Management of material topics

ESRS S1­5 Targets

ESRS S2­2 Processes for engaging with value chain workers about impacts

ESRS S2­4 Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those action

ESRS S2­5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

ESRS

3-3

ESRS S4­1 Policies related to consumers and end­users

ESRS S4­2 Processes for engaging with consumers and end­users about impacts

ESRS S4­4 Taking action on material impacts on consumers and end­users,

ESRS S4­2

ESRS S4­4

ESRS S4­5