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IMPLEMENTATION OF A CODE OF ETHICS
As well as individual
measures designed to ensure the integrity of companies’
management, the Sarbanes-Oxley Act requires companies to
have a code of ethics for senior financial officers; that is, the
CEO, the CFO, the heads of controlling and accounting, and
anyone else with a similar role. The code should encourage
honest behavior, appropriate treatment of conflicts of interest,
and proper financial reporting.
In 2003, SAP introduced a Code of Business
Conduct, which applies to the areas and people covered by this
requirement. The Code, which is binding on all SAP employees,
sets the standard for how they interact with customers,
partners, competitors, and vendors. The Code is a statement
of SAP’s commitment to safeguarding against misleading its
investors and customers, unfair competitive practices, and corruption.
To allow for differences in culture and legal systems
and to help employees in SAP’s subsidiaries to identify more
closely with the Code of Business Conduct, SAP has not implemented
a single code across the SAP Group. Instead, SAP
framed Group-wide minimum standards in a master framework.
During 2003, all of the companies in the SAP Group
adopted similar codes of their own. These individual codes of
conduct must at least reflect the master code, but they may
contain additional rules, and their rules may be more stringent
and take local differences into consideration.
RISK MANAGEMENT
Both the Sarbanes-Oxley Act in the
United States and the German Supervision and Transparency
in the Area of Enterprise Act (KonTraG) place high demands
on SAP’s risk management systems. Systematic risk management
helps to identify risks, which is an important part of
value-oriented company management. SAP has implemented
a number of control mechanisms across the SAP Group to
enable management to recognize in good time and control
the entire range of risks and to develop effective measures to
minimize them. These measures include Group-wide reporting
and structured management and control systems. The
Company’s internal audit service and the Supervisory Board
are also intensively engaged in risk management. To underscore
the importance of taking a global risk management
approach, the Executive Board created the Global Risk Management
team to coordinate, standardize, and optimize SAP’s
existing risk management processes. |
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