SAP Anti-Bribery and Anti-Corruption Supplemental Terms for Suppliers
SAP Anti-Bribery and Anti-Corruption Supplemental Terms for Suppliers Stáhnout dokumentPUBLIC
SAP Anti-Bribery and Anti-Corruption Supplemental
Terms for Suppliers
Version: 1
Date: December 2025
Document Classification: PUBLIC
SAP Anti-Bribery and Anti-Corruption Supplemental
Terms for Suppliers
Version: 1
Date: December 2025
Document Classification: PUBLIC
© 2026 SAP SE or an SAP affiliate company. All rights reserved. See Legal Notice on www.sap.com/legal-notice for use terms, disclaimers, disclosures, or restrictions related to this material. 2 / 6
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Table of contents
1.Applicability....................................................................................................................................... 3
1.1.Purpose .......................................................................................................................................... 3
2.Definitions ......................................................................................................................................... 3
3.Compliance with laws, FCPA and SAP Supplier Code of Conduct..................................................... 4
4.Prohibited Parties/Prohibited Payments .......................................................................................... 4
5.Conviction ......................................................................................................................................... 5
6.Audit............ ....................................................................................................................................... 5
7.Breach of representation............ ....................................................................................................... 5
8.Disclosure............ ............................................................................................................................... 5
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Table of contents
1.Applicability....................................................................................................................................... 3
1.1.Purpose .......................................................................................................................................... 3
2.Definitions ......................................................................................................................................... 3
3.Compliance with laws, FCPA and SAP Supplier Code of Conduct..................................................... 4
4.Prohibited Parties/Prohibited Payments .......................................................................................... 4
5.Conviction ......................................................................................................................................... 5
6.Audit............ ....................................................................................................................................... 5
7.Breach of representation............ ....................................................................................................... 5
8.Disclosure............ ............................................................................................................................... 5
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1. Applicability
For purposes of these Supplemental Terms, the following documents are considered “Purchase Orders”: (i)
Purchase Orders created and submitted by SAP via Ariba procurement system, and (ii) Statement of Works
or Work Orders created and submitted by SAP via Fieldglass procurement system. The obligations apply
whenever Supplier provides services involving interaction with Government Officials or public sector
customers, as identified in the corresponding Purchase Order or Work Order.
This document is intended for use when services procured by SAP, or on SAP’s behalf, involve interaction
with a Government Official. These services may be provided directly to SAP or, at SAP’s request, to an SAP
customer. Interactions include but are not limited to discussions, emails, invitations, meetings, and transfer
of funds, or documents.
The obligations set forth here apply to all current and future Purchase Orders under which Supplier provides
services involving interaction with public sector customers or Government Officials, whether such services
are performed directly for SAP or, at SAP’s request, for an SAP customer. These obligations are continuing in
nature and apply for the duration of Supplier’s engagement on such projects.
These Supplemental Terms supplement the SAP General Terms and Conditions (GTCs) and prevail only in
case of inconsistency on the same subject matter.
1.1. Purpose
The purpose of these Supplemental Terms is to safeguard compliance with applicable anti-bribery and anti-
corruption (ABAC) laws, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA), the UK
Bribery Act, and similar legislation worldwide, as well as SAP’s Supplier Code of Conduct. These Supplemental
Terms supplement the Purchase Order and prevail in the event of any inconsistency.
2. Definitions
For the purpose of these Supplemental Terms, “SAP” means SAP SE and any SAP Subsidiary.
For the purpose of these Supplemental Terms, “SAP Subsidiary” means any legal entity in which SAP SE
directly or indirectly holds more than fifty percent (50%) of the shares or voting rights, or any entity that is
otherwise under the direct or indirect control of SAP SE.
For the purpose of these Supplemental Terms, “Government Official” means any individual who holds an
appointed or elected position, or otherwise acts on behalf of, a government entity, including but not limited
to:
· officers or employees of a government department, agency, or instrumentality;
· officers or employees of a state-owned or state-controlled enterprise, school, hospital or other entity;
· officials of political parties or candidates for political office;
PUBLIC
1. Applicability
For purposes of these Supplemental Terms, the following documents are considered “Purchase Orders”: (i)
Purchase Orders created and submitted by SAP via Ariba procurement system, and (ii) Statement of Works
or Work Orders created and submitted by SAP via Fieldglass procurement system. The obligations apply
whenever Supplier provides services involving interaction with Government Officials or public sector
customers, as identified in the corresponding Purchase Order or Work Order.
This document is intended for use when services procured by SAP, or on SAP’s behalf, involve interaction
with a Government Official. These services may be provided directly to SAP or, at SAP’s request, to an SAP
customer. Interactions include but are not limited to discussions, emails, invitations, meetings, and transfer
of funds, or documents.
The obligations set forth here apply to all current and future Purchase Orders under which Supplier provides
services involving interaction with public sector customers or Government Officials, whether such services
are performed directly for SAP or, at SAP’s request, for an SAP customer. These obligations are continuing in
nature and apply for the duration of Supplier’s engagement on such projects.
These Supplemental Terms supplement the SAP General Terms and Conditions (GTCs) and prevail only in
case of inconsistency on the same subject matter.
1.1. Purpose
The purpose of these Supplemental Terms is to safeguard compliance with applicable anti-bribery and anti-
corruption (ABAC) laws, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA), the UK
Bribery Act, and similar legislation worldwide, as well as SAP’s Supplier Code of Conduct. These Supplemental
Terms supplement the Purchase Order and prevail in the event of any inconsistency.
2. Definitions
For the purpose of these Supplemental Terms, “SAP” means SAP SE and any SAP Subsidiary.
For the purpose of these Supplemental Terms, “SAP Subsidiary” means any legal entity in which SAP SE
directly or indirectly holds more than fifty percent (50%) of the shares or voting rights, or any entity that is
otherwise under the direct or indirect control of SAP SE.
For the purpose of these Supplemental Terms, “Government Official” means any individual who holds an
appointed or elected position, or otherwise acts on behalf of, a government entity, including but not limited
to:
· officers or employees of a government department, agency, or instrumentality;
· officers or employees of a state-owned or state-controlled enterprise, school, hospital or other entity;
· officials of political parties or candidates for political office;
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· officers or employees of public international organization or any department or agency thereof (such as the
IMF, World Bank, or United Nations);
· any person acting in an official capacity for, or with influence over, a governmental entity; or
. any other individual who is treated as a government official under applicable law.
3. Compliance with laws, FCPA and SAP Supplier Code of Conduct
Supplier shall ensure that all agents, subcontractors, employees, associates, representatives, and any other
persons acting on its behalf, conduct its operations at all times in strict compliance with all applicable laws,
rules and regulations, including the US Foreign Corrupt Practices Act (FCPA), UK Bribery Act and SAP Supplier
Code of Conduct. Any violation shall constitute a material breach of the Purchase Order, entitling SAP to
terminate it immediately.
Supplier shall not take any action that would subject SAP to penalties under applicable laws or regulations,
nor obtain or provide information that is unauthorized, illegal, or unethical.
4. Prohibited parties/Prohibited payments
Supplier shall not pay or tender directly or indirectly any commission or finders or referral fee to any firm,
organization or person in connection with its activities on behalf of SAP.
Supplier shall not make, offer or promise any payments or gifts directly or indirectly to any employee of the
potential customers. Any business entertainment offered to the potential customer or customers must
comply with the spirit and letter of the limits established in the relevant local SAP Supplier Code of Conduct.
Supplier shall not pay or offer or agree to pay any political contribution or donation in respect of any business
for which it provides services to SAP.
Supplier represents and warrants to SAP that:
Supplier, its agents, subcontractors, employees, associates, representatives, and any other person acting on
its behalf have not directly or indirectly paid, offered or promised to pay, or authorized the payment of, and
will not directly or indirectly pay, offer or promise to pay, or authorize the payment of, any monies or gifts or
anything of value to any employee or representative of a customer or prospect, Government Official or
employee, political party official or candidate, or officer or employee of any public international organization,
or an immediate family member of such persons (Prohibited Parties) for the purpose of influencing their acts
or decisions in order to secure or retain business on behalf of SAP (Prohibited Payments);
Supplier further represents that neither it, nor any individual acting on its behalf, is or has been a Prohibited
Party during the 90 days preceding these Supplemental Terms or Purchase Order and shall notify SAP
immediately if this status changes. SAP may terminate the Purchase Order upon such notice.
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· officers or employees of public international organization or any department or agency thereof (such as the
IMF, World Bank, or United Nations);
· any person acting in an official capacity for, or with influence over, a governmental entity; or
. any other individual who is treated as a government official under applicable law.
3. Compliance with laws, FCPA and SAP Supplier Code of Conduct
Supplier shall ensure that all agents, subcontractors, employees, associates, representatives, and any other
persons acting on its behalf, conduct its operations at all times in strict compliance with all applicable laws,
rules and regulations, including the US Foreign Corrupt Practices Act (FCPA), UK Bribery Act and SAP Supplier
Code of Conduct. Any violation shall constitute a material breach of the Purchase Order, entitling SAP to
terminate it immediately.
Supplier shall not take any action that would subject SAP to penalties under applicable laws or regulations,
nor obtain or provide information that is unauthorized, illegal, or unethical.
4. Prohibited parties/Prohibited payments
Supplier shall not pay or tender directly or indirectly any commission or finders or referral fee to any firm,
organization or person in connection with its activities on behalf of SAP.
Supplier shall not make, offer or promise any payments or gifts directly or indirectly to any employee of the
potential customers. Any business entertainment offered to the potential customer or customers must
comply with the spirit and letter of the limits established in the relevant local SAP Supplier Code of Conduct.
Supplier shall not pay or offer or agree to pay any political contribution or donation in respect of any business
for which it provides services to SAP.
Supplier represents and warrants to SAP that:
Supplier, its agents, subcontractors, employees, associates, representatives, and any other person acting on
its behalf have not directly or indirectly paid, offered or promised to pay, or authorized the payment of, and
will not directly or indirectly pay, offer or promise to pay, or authorize the payment of, any monies or gifts or
anything of value to any employee or representative of a customer or prospect, Government Official or
employee, political party official or candidate, or officer or employee of any public international organization,
or an immediate family member of such persons (Prohibited Parties) for the purpose of influencing their acts
or decisions in order to secure or retain business on behalf of SAP (Prohibited Payments);
Supplier further represents that neither it, nor any individual acting on its behalf, is or has been a Prohibited
Party during the 90 days preceding these Supplemental Terms or Purchase Order and shall notify SAP
immediately if this status changes. SAP may terminate the Purchase Order upon such notice.
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5. Conviction
Supplier represents and warrants that neither Supplier nor any of its agents, subcontractors, employees,
associates, representatives, direct or indirect owners, or any other person acting on its behalf has been
convicted of or pleaded guilty to an offence involving fraud, corruption or other dishonest conduct, and that
it is not now listed by any government agency as debarred, suspended, and proposed for suspension or
debarment or otherwise ineligible for government procurement programs.
6. Audit
SAP shall have the right to audit the activities and records of Supplier and its employees, associates, agents,
subcontractors or any other person acting on its behalf. In particular, in the event SAP has reason to believe
that a breach of any of the representations and warranties made by the Supplier under any mutually agreed
Purchase Order has occurred or may occur, SAP shall have the right perform an audit of the activities and
records of Supplier or any of its employees or associates in order to satisfy itself that no such breach has
occurred. Upon Supplier’s written request, SAP shall select an independent third party to conduct such
audit. Supplier shall cause its Supplier Personnel to fully cooperate in any audit conducted by or on behalf
of SAP.
7. Breach of representation
In the event SAP has reason to believe that a breach of any of the representations and warranties made by
Supplier under the Purchase Order has occurred or may occur, SAP may withhold further payments until such
time as it has received confirmation to its satisfaction that no such breach has occurred or will occur. SAP
shall not be liable to Supplier for any claims, losses or damages whatsoever related to its decision to withhold
payments under this provision.
In the event of a breach of any of the representations and warranties made by Supplier under the Purchase
Order, the Purchase Order shall be void ab initio without the requirement of any written notice of
cancellation. All claims for payment by Supplier shall be automatically terminated and cancelled and all
payments previously paid shall be forthwith refunded to SAP by Supplier. Supplier shall further indemnify
and hold SAP harmless against any and all claims, losses or damages arising from or related to such breach
or the cancellation of the Purchase Order, or both.
8. Disclosure
SAP may disclose these Supplemental Terms and the Purchase Order to government agencies or other parties
with a legitimate need for such information.
Supplier certifies that neither it nor its personnel are members of the customer ́s management or in a
position to influence decisions related to services provided under these Supplemental Terms and the
Purchase Order.
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5. Conviction
Supplier represents and warrants that neither Supplier nor any of its agents, subcontractors, employees,
associates, representatives, direct or indirect owners, or any other person acting on its behalf has been
convicted of or pleaded guilty to an offence involving fraud, corruption or other dishonest conduct, and that
it is not now listed by any government agency as debarred, suspended, and proposed for suspension or
debarment or otherwise ineligible for government procurement programs.
6. Audit
SAP shall have the right to audit the activities and records of Supplier and its employees, associates, agents,
subcontractors or any other person acting on its behalf. In particular, in the event SAP has reason to believe
that a breach of any of the representations and warranties made by the Supplier under any mutually agreed
Purchase Order has occurred or may occur, SAP shall have the right perform an audit of the activities and
records of Supplier or any of its employees or associates in order to satisfy itself that no such breach has
occurred. Upon Supplier’s written request, SAP shall select an independent third party to conduct such
audit. Supplier shall cause its Supplier Personnel to fully cooperate in any audit conducted by or on behalf
of SAP.
7. Breach of representation
In the event SAP has reason to believe that a breach of any of the representations and warranties made by
Supplier under the Purchase Order has occurred or may occur, SAP may withhold further payments until such
time as it has received confirmation to its satisfaction that no such breach has occurred or will occur. SAP
shall not be liable to Supplier for any claims, losses or damages whatsoever related to its decision to withhold
payments under this provision.
In the event of a breach of any of the representations and warranties made by Supplier under the Purchase
Order, the Purchase Order shall be void ab initio without the requirement of any written notice of
cancellation. All claims for payment by Supplier shall be automatically terminated and cancelled and all
payments previously paid shall be forthwith refunded to SAP by Supplier. Supplier shall further indemnify
and hold SAP harmless against any and all claims, losses or damages arising from or related to such breach
or the cancellation of the Purchase Order, or both.
8. Disclosure
SAP may disclose these Supplemental Terms and the Purchase Order to government agencies or other parties
with a legitimate need for such information.
Supplier certifies that neither it nor its personnel are members of the customer ́s management or in a
position to influence decisions related to services provided under these Supplemental Terms and the
Purchase Order.