2024 Statement SAP UK Modern Slavery Statement
2024 Statement SAP UK Modern Slavery Statement Lae alla document1
2024
Modern Slavery Statement
This statement is made on behalf of SAP UK Limited (“SAP UK”), as approved by its board,
pursuant to Section 54 of the Modern Slavery Act 2015 Act covering the financial year ending
31 December 2024. It sets out the steps that SAP UK has taken and is continuing to take to
assess and address the risk of modern slavery practices in our supply chain.
SAP UK has prepared this statement with input from SAP’s parent company, SAP SE. SAP UK
has also consulted and aligned with SAP Australia Limited in preparing this statement. SAP UK
does not own or control any other operating entities.
References in this statement to “SAP”, “we”, “us” and “our” are to SAP SE and, as applicable,
the SAP group companies.
SAP Business Structure
SAP (UK) Limited is a subsidiary of SAP SE, a European multinational software and services
corporation and a market leader in enterprise application software as well as in enterprise
resource management applications, supply chain management applications, procurement
applications software, travel and expense management software, and enterprise resource
planning software, among others. In addition, SAP delivers relevant, reliable, responsible AI built
into SAP business solutions. SAP SE is headquartered in Walldorf, Germany and has a global
presence.
SAP UK is a limited liability company with its registered address at Clockhouse Place, Bedfont
Road, Feltham, Middlesex, TW14 8HD. The customer base comprises customers in major
industries, including Sovereign Cloud customers such as public services, critical infrastructure,
for example, healthcare, energy and natural resources, utilities, financial services and
telecommunications, retail and consumer packaged goods, as well as insurance. SAP UK has
been in operation for over 38 years.
SAP’s purpose is to “help the world run better and improve people’s lives.” Our products and
services aim to help our customers both meet the challenges and take advantage of the
opportunities presented by today’s rapidly changing world.
As a global leader in enterprise applications and business AI, SAP stands at the intersection of
business and technology. For over 50 years, organisations worldwide have trusted SAP to
unlock their full potential by seamlessly integrating critical business operations across finance,
procurement, human resources, supply chain, and customer experience. More information on
SAP’s offerings is available at SAP Products. SAP’s integrated applications connect all parts of
a business into an intelligent suite built on a fully digital platform. Today, SAP serves more than
230 million cloud users with over 100 solutions covering all business functions, offering the
largest cloud portfolio of any provider.
More information on SAP’s structure and offerings is available in the SAP Integrated Report
2024.Docusign Envelope ID: 7A3971C2-5628-4D7D-A6FF-CAF016711E2B
2024
Modern Slavery Statement
This statement is made on behalf of SAP UK Limited (“SAP UK”), as approved by its board,
pursuant to Section 54 of the Modern Slavery Act 2015 Act covering the financial year ending
31 December 2024. It sets out the steps that SAP UK has taken and is continuing to take to
assess and address the risk of modern slavery practices in our supply chain.
SAP UK has prepared this statement with input from SAP’s parent company, SAP SE. SAP UK
has also consulted and aligned with SAP Australia Limited in preparing this statement. SAP UK
does not own or control any other operating entities.
References in this statement to “SAP”, “we”, “us” and “our” are to SAP SE and, as applicable,
the SAP group companies.
SAP Business Structure
SAP (UK) Limited is a subsidiary of SAP SE, a European multinational software and services
corporation and a market leader in enterprise application software as well as in enterprise
resource management applications, supply chain management applications, procurement
applications software, travel and expense management software, and enterprise resource
planning software, among others. In addition, SAP delivers relevant, reliable, responsible AI built
into SAP business solutions. SAP SE is headquartered in Walldorf, Germany and has a global
presence.
SAP UK is a limited liability company with its registered address at Clockhouse Place, Bedfont
Road, Feltham, Middlesex, TW14 8HD. The customer base comprises customers in major
industries, including Sovereign Cloud customers such as public services, critical infrastructure,
for example, healthcare, energy and natural resources, utilities, financial services and
telecommunications, retail and consumer packaged goods, as well as insurance. SAP UK has
been in operation for over 38 years.
SAP’s purpose is to “help the world run better and improve people’s lives.” Our products and
services aim to help our customers both meet the challenges and take advantage of the
opportunities presented by today’s rapidly changing world.
As a global leader in enterprise applications and business AI, SAP stands at the intersection of
business and technology. For over 50 years, organisations worldwide have trusted SAP to
unlock their full potential by seamlessly integrating critical business operations across finance,
procurement, human resources, supply chain, and customer experience. More information on
SAP’s offerings is available at SAP Products. SAP’s integrated applications connect all parts of
a business into an intelligent suite built on a fully digital platform. Today, SAP serves more than
230 million cloud users with over 100 solutions covering all business functions, offering the
largest cloud portfolio of any provider.
More information on SAP’s structure and offerings is available in the SAP Integrated Report
2024.Docusign Envelope ID: 7A3971C2-5628-4D7D-A6FF-CAF016711E2B
2
Modern Slavery and Human Rights
At SAP, we believe we have a responsibility to respect human rights throughout all our business
operations. We have policies and procedures to combat the risk of slavery in our business and
our supply chains and to ensure a healthy working environment for all our staff.
SAP respects and upholds the values of the International Bill of Human Rights and the
International Labour Organisation’s (ILO) Core Labour Rights Conventions. In addition, SAP
takes guidance from international frameworks such as the United Nations Guiding Principles
on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational
Enterprises on Responsible Business Conduct, to integrate human rights considerations into
SAP standard business practices, policies, and processes. SAP has signed the United Nations
Global Compact, pledging to align its strategies and operations with universal principles related
to human rights, labour, the environment, and anti-corruption.
Our Global Human Rights Commitment Statement describes SAP’s human rights-related action
areas including modern slavery, human rights governance and risk management system,
prioritised risks, preventive and remedial measures, and expectations placed on employees
and all business partners. It applies to all SAP operations worldwide. The current version is
available on our SAP Global Human Rights Commitment Statement website and has been
rolled out globally to employees and suppliers. Ultimate responsibility for our Global Human
Rights Commitment Statement lies with the SAP Executive Board. The current version of the
Human Rights Commitment Statement is available at SAP Global Human Rights Commitment
Statement.
SAP is committed to respecting its employees' fundamental rights at work. As outlined in SAP’s
Global Code of Ethics and Business Conduct for Employees, employees are also expected to
comply with all applicable laws, regulations, company policies, and fundamental principles
relating to human rights.
We do not accept forced, bonded, or involuntary prison labour nor any form of human trafficking.
Employment at SAP is voluntary. Employees are free to leave their jobs after any required
notice periods, where applicable and consistent with their employment contracts. In SAP’s
recruiting and hiring processes we ensure that employees do not have to pay recruitment fees.
We also make sure that they are not required to lodge deposits, identity papers, or any other
documents that might limit the worker’s legal status, their freedom to travel or the ability to leave
their job temporarily or permanently upon commencing employment with SAP.
SAP respects the rights of our employees to organise and to be represented by trade unions
and other bona fide representatives of employees in accordance with local laws and engage in
a constructive dialogue with employee representatives. Where local laws restrict the
establishment of certain employee representations, we are open to other forms of employee
representation that are not prohibited under local law.
These employee representative bodies consist of elected union members and/or non-union
members, and are consulted by SAP management mainly on topics that define the work
environment and work processes. Collective bargaining agreements with unions are made in
countries where legally required.
SAP does not tolerate child labor. This is ensured via HR recruiting and hiring processes and
governance. To foster quality education and job opportunities, we offer different vocationalDocusign Envelope ID: 7A3971C2-5628-4D7D-A6FF-CAF016711E2B
Modern Slavery and Human Rights
At SAP, we believe we have a responsibility to respect human rights throughout all our business
operations. We have policies and procedures to combat the risk of slavery in our business and
our supply chains and to ensure a healthy working environment for all our staff.
SAP respects and upholds the values of the International Bill of Human Rights and the
International Labour Organisation’s (ILO) Core Labour Rights Conventions. In addition, SAP
takes guidance from international frameworks such as the United Nations Guiding Principles
on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational
Enterprises on Responsible Business Conduct, to integrate human rights considerations into
SAP standard business practices, policies, and processes. SAP has signed the United Nations
Global Compact, pledging to align its strategies and operations with universal principles related
to human rights, labour, the environment, and anti-corruption.
Our Global Human Rights Commitment Statement describes SAP’s human rights-related action
areas including modern slavery, human rights governance and risk management system,
prioritised risks, preventive and remedial measures, and expectations placed on employees
and all business partners. It applies to all SAP operations worldwide. The current version is
available on our SAP Global Human Rights Commitment Statement website and has been
rolled out globally to employees and suppliers. Ultimate responsibility for our Global Human
Rights Commitment Statement lies with the SAP Executive Board. The current version of the
Human Rights Commitment Statement is available at SAP Global Human Rights Commitment
Statement.
SAP is committed to respecting its employees' fundamental rights at work. As outlined in SAP’s
Global Code of Ethics and Business Conduct for Employees, employees are also expected to
comply with all applicable laws, regulations, company policies, and fundamental principles
relating to human rights.
We do not accept forced, bonded, or involuntary prison labour nor any form of human trafficking.
Employment at SAP is voluntary. Employees are free to leave their jobs after any required
notice periods, where applicable and consistent with their employment contracts. In SAP’s
recruiting and hiring processes we ensure that employees do not have to pay recruitment fees.
We also make sure that they are not required to lodge deposits, identity papers, or any other
documents that might limit the worker’s legal status, their freedom to travel or the ability to leave
their job temporarily or permanently upon commencing employment with SAP.
SAP respects the rights of our employees to organise and to be represented by trade unions
and other bona fide representatives of employees in accordance with local laws and engage in
a constructive dialogue with employee representatives. Where local laws restrict the
establishment of certain employee representations, we are open to other forms of employee
representation that are not prohibited under local law.
These employee representative bodies consist of elected union members and/or non-union
members, and are consulted by SAP management mainly on topics that define the work
environment and work processes. Collective bargaining agreements with unions are made in
countries where legally required.
SAP does not tolerate child labor. This is ensured via HR recruiting and hiring processes and
governance. To foster quality education and job opportunities, we offer different vocationalDocusign Envelope ID: 7A3971C2-5628-4D7D-A6FF-CAF016711E2B
3
training programs which may include minors under the age of 18. They receive a special
employment contract and special care is paid to safeguard limitation of working hours and
protect their well-being.
We ensure that our workers are compensated with wages and benefits that meet or exceed
the legally required minimum. Laws relating to pay, employment benefits, hours of work, time
off, leaves of absence and other terms and conditions of employment vary from country to
country. We are expected to comply with all applicable employment-related laws. This is
ensured via SAP HR processes and governance.
Due Diligence Processes
SAP’s Human Rights Commitment Statement has a global scope, it applies to SAP operations
worldwide. SAP also expects all business partners (for example, suppliers, partners, customers)
to respect human rights and act in line with global human rights frameworks.
The Human Rights Commitment Statement applies to SAP operations worldwide. We expect
all our suppliers and partners to respect human rights and to avoid complicity in human rights
abuses. SAP’s Supplier Code of Conduct and Partner Code of Conduct require our suppliers
and partners to uphold labour rights and to provide a safe and healthy work environment for all
employees. SAP also has established contractual assurances through the codes of conduct for
suppliers and partners, which are an integral part of SAP’s respective General Terms &
Conditions.
Supply Chain
SAP operates a global value chain, providing cloud-based software, services, and support to
customers worldwide. While SAP does not manufacture any physical products, it relies on a
complex supply chain to support its daily operations in offices and data centres. This supply
chain is a crucial part of SAP’s upstream value chain and involves the procurement of
technology, hardware, and services, as well as the management of relationships with suppliers
and partners to deliver integrated solutions.
SAP’s supply chain consists of thousands of suppliers from around the world who provide
products and services essential for the development and delivery of SAP’s offerings. Key
procurement items include hyperscaler services and IT hardware.
We acknowledge that in our extended supply chains, we are exposed to risks in the area of
working conditions, environment or health and safety, especially when purchasing products or
services from high-risk industries or when purchasing in countries with higher risks to human
rights. SAP actively manages and assesses the social and ethical impacts of its supply chain,
with a focus on protecting vulnerable groups and fostering responsible business practices
throughout its value chain.
Risk Assessment and Management
In our commitment to addressing modern slavery risks, SAP conducts a comprehensive risk
analysis across the value chain to identify and prioritise human rights risks, ensuring
compliance with relevant legal frameworks. We continuously monitor and evolve this process
and seek to embed it into our organisation and business relationships.Docusign Envelope ID: 7A3971C2-5628-4D7D-A6FF-CAF016711E2B
training programs which may include minors under the age of 18. They receive a special
employment contract and special care is paid to safeguard limitation of working hours and
protect their well-being.
We ensure that our workers are compensated with wages and benefits that meet or exceed
the legally required minimum. Laws relating to pay, employment benefits, hours of work, time
off, leaves of absence and other terms and conditions of employment vary from country to
country. We are expected to comply with all applicable employment-related laws. This is
ensured via SAP HR processes and governance.
Due Diligence Processes
SAP’s Human Rights Commitment Statement has a global scope, it applies to SAP operations
worldwide. SAP also expects all business partners (for example, suppliers, partners, customers)
to respect human rights and act in line with global human rights frameworks.
The Human Rights Commitment Statement applies to SAP operations worldwide. We expect
all our suppliers and partners to respect human rights and to avoid complicity in human rights
abuses. SAP’s Supplier Code of Conduct and Partner Code of Conduct require our suppliers
and partners to uphold labour rights and to provide a safe and healthy work environment for all
employees. SAP also has established contractual assurances through the codes of conduct for
suppliers and partners, which are an integral part of SAP’s respective General Terms &
Conditions.
Supply Chain
SAP operates a global value chain, providing cloud-based software, services, and support to
customers worldwide. While SAP does not manufacture any physical products, it relies on a
complex supply chain to support its daily operations in offices and data centres. This supply
chain is a crucial part of SAP’s upstream value chain and involves the procurement of
technology, hardware, and services, as well as the management of relationships with suppliers
and partners to deliver integrated solutions.
SAP’s supply chain consists of thousands of suppliers from around the world who provide
products and services essential for the development and delivery of SAP’s offerings. Key
procurement items include hyperscaler services and IT hardware.
We acknowledge that in our extended supply chains, we are exposed to risks in the area of
working conditions, environment or health and safety, especially when purchasing products or
services from high-risk industries or when purchasing in countries with higher risks to human
rights. SAP actively manages and assesses the social and ethical impacts of its supply chain,
with a focus on protecting vulnerable groups and fostering responsible business practices
throughout its value chain.
Risk Assessment and Management
In our commitment to addressing modern slavery risks, SAP conducts a comprehensive risk
analysis across the value chain to identify and prioritise human rights risks, ensuring
compliance with relevant legal frameworks. We continuously monitor and evolve this process
and seek to embed it into our organisation and business relationships.Docusign Envelope ID: 7A3971C2-5628-4D7D-A6FF-CAF016711E2B
4
SAP’s Human Rights Due Diligence program assesses and prioritises the material matters
concerning our own employees and value chain workers, such as adequate wages, health and
safety, gender equality, equal pay for work of equal value, measures against violence and
harassment, and eradication of child and forced labour. We use Environmental, Social and
Governance risk management software to ensure we have a structured process for assessing
potential impacts of our own operations and those of our direct (“Tier 1”) suppliers. For
information about our suppliers, see the Workers in the Value Chain section of the SAP
Integrated Report 2024.
Our risk assessment process includes the following steps:
• Step 1: Performing an abstract risk analysis in which country-specific and industry-
specific risks related to human rights and environmental standards are evaluated by
referencing quantitative indicators from the World Bank and the United Nations and
qualitative data from sources such as the Corporate Social Responsibility Risk Check of
the German Helpdesk on Business and Human Rights.
• Step 2: Performing a concrete risk analysis in which we identify risks from our own
operations and from our direct suppliers. For our own operations, we examine high-risk
clusters more closely by interviewing experts, drawing on internal data from, for example,
our complaints mechanisms and environmental management system, and queries from
the country-specific financial risk identification process.
SAP also conducts detailed assessments of high-risk direct suppliers, particularly those
with significant spend (that is, of more than €50,000) by using questionnaires to gather
information about their response to the risks that were identified.
• Step 3: Prioritising the assessment of potential negative impacts related to our own
operations and value chain based on criteria such as the nature of our business activities,
our ability to influence suppliers, probability and severity (scale, scope, remediation) of
potential violations, and the nature of our causal contribution.
The findings are integrated into regular risk analysis that is carried out at least annually and as
required on an ad hoc basis. SAP has also used and will continue to use an external service
provider to conduct risk analysis.
SAP also assesses potential impacts related to our indirect (“tier 2-n”) upstream supply chain
and downstream value chain. For example, we use impact measurement and valuation to gain
an understanding of positive and negative impacts in our value chain. For more information about
our impact measurement and valuation, see the “Impact Valuation Approach” section of the SAP
Integrated Report 2024.
Risks of Modern Slavery in our Supply Chains
SAP UK continues to monitor the risks of modern slavery in its supply chain, and has identified
the following focus areas to strengthen controls and processes:
Employees and contractors who support SAP’s internal business operations, which
includes labour in developing countries who provide software IT/ HR/ Finance shared
service support services to SAP;
Employees and contractors who support maintenance of SAP’s software and developmentDocusign Envelope ID: 7A3971C2-5628-4D7D-A6FF-CAF016711E2B
SAP’s Human Rights Due Diligence program assesses and prioritises the material matters
concerning our own employees and value chain workers, such as adequate wages, health and
safety, gender equality, equal pay for work of equal value, measures against violence and
harassment, and eradication of child and forced labour. We use Environmental, Social and
Governance risk management software to ensure we have a structured process for assessing
potential impacts of our own operations and those of our direct (“Tier 1”) suppliers. For
information about our suppliers, see the Workers in the Value Chain section of the SAP
Integrated Report 2024.
Our risk assessment process includes the following steps:
• Step 1: Performing an abstract risk analysis in which country-specific and industry-
specific risks related to human rights and environmental standards are evaluated by
referencing quantitative indicators from the World Bank and the United Nations and
qualitative data from sources such as the Corporate Social Responsibility Risk Check of
the German Helpdesk on Business and Human Rights.
• Step 2: Performing a concrete risk analysis in which we identify risks from our own
operations and from our direct suppliers. For our own operations, we examine high-risk
clusters more closely by interviewing experts, drawing on internal data from, for example,
our complaints mechanisms and environmental management system, and queries from
the country-specific financial risk identification process.
SAP also conducts detailed assessments of high-risk direct suppliers, particularly those
with significant spend (that is, of more than €50,000) by using questionnaires to gather
information about their response to the risks that were identified.
• Step 3: Prioritising the assessment of potential negative impacts related to our own
operations and value chain based on criteria such as the nature of our business activities,
our ability to influence suppliers, probability and severity (scale, scope, remediation) of
potential violations, and the nature of our causal contribution.
The findings are integrated into regular risk analysis that is carried out at least annually and as
required on an ad hoc basis. SAP has also used and will continue to use an external service
provider to conduct risk analysis.
SAP also assesses potential impacts related to our indirect (“tier 2-n”) upstream supply chain
and downstream value chain. For example, we use impact measurement and valuation to gain
an understanding of positive and negative impacts in our value chain. For more information about
our impact measurement and valuation, see the “Impact Valuation Approach” section of the SAP
Integrated Report 2024.
Risks of Modern Slavery in our Supply Chains
SAP UK continues to monitor the risks of modern slavery in its supply chain, and has identified
the following focus areas to strengthen controls and processes:
Employees and contractors who support SAP’s internal business operations, which
includes labour in developing countries who provide software IT/ HR/ Finance shared
service support services to SAP;
Employees and contractors who support maintenance of SAP’s software and developmentDocusign Envelope ID: 7A3971C2-5628-4D7D-A6FF-CAF016711E2B
5
of solutions for SAP’s customers which includes software development and maintenance
personnel in developing countries;
Suppliers of corporate and facilities management services to SAP such as cleaning and
facilities contractors;
Suppliers who provide data centre facilities and services to SAP;
Suppliers who provide external staffing to SAP;
Suppliers of stationery, kitchen supplies, marketing supplies; and
Other suppliers located in developing countries.
SAP UK assesses the effectiveness of its actions by monitoring whether any incidences of
modern slavery have been identified through its risk assessment and audit processes. We
continue to review our processes in conjunction with the broader SAP group to help assess and
address modern slavery risks in our operations and supply chains.
Key Performance Indicators
We continually assess the effectiveness of the measures we have in place to identify and
manage modern slavery risks. Examples of other performance indicators SAP UK has in place
include:
- Keeping record and measuring percentage of completion rate of employees conducting
their annual compliance training;
- Number of whistleblowing alerts; and
- Number of employee discrimination complaints.
We encourage all employees, including temporary external staff, to report conduct that violates
our policies. Our whistleblower reporting tool is also available to external groups.
Whistleblower Reporting Tool and Policy
SAP recognises the importance and encourages the reporting of potential misconduct or a
potential improper state of affairs relating to the Company. To foster the goal that every SAP
employee worldwide can be heard and speak out without fear and retaliation, we have
established a Global Ombuds Office which operates as an informal, independent, and
confidential channel on top of the formal complaint mechanisms in place, including our Speak
Out whistleblower reporting tool.
Speak Out at SAP is SAP’s independently hosted whistleblower reporting tool, through which
any matter or concern can be reported easily, and, if desired, anonymously. The tool is available
24 hours a day, seven days a week, both internally to SAP employees and externally to
concerned parties, including customers, suppliers, and partners. The tool is managed by SAP.
Reports may be submitted either directly by the reporter through the Internet based portal, or by
phone with local language support across the globe to maximise accessibility for reporters. In all
cases, SAP continues to maintain a strict non-retaliation policy.
Through this tool, we encourage all employees, including temporary external staff, to report
conduct that violates our policies. Beyond Speak Out at SAP, we provide further reporting
channels, including the internal ticketed system, a postal address for written submissions, asDocusign Envelope ID: 7A3971C2-5628-4D7D-A6FF-CAF016711E2B
of solutions for SAP’s customers which includes software development and maintenance
personnel in developing countries;
Suppliers of corporate and facilities management services to SAP such as cleaning and
facilities contractors;
Suppliers who provide data centre facilities and services to SAP;
Suppliers who provide external staffing to SAP;
Suppliers of stationery, kitchen supplies, marketing supplies; and
Other suppliers located in developing countries.
SAP UK assesses the effectiveness of its actions by monitoring whether any incidences of
modern slavery have been identified through its risk assessment and audit processes. We
continue to review our processes in conjunction with the broader SAP group to help assess and
address modern slavery risks in our operations and supply chains.
Key Performance Indicators
We continually assess the effectiveness of the measures we have in place to identify and
manage modern slavery risks. Examples of other performance indicators SAP UK has in place
include:
- Keeping record and measuring percentage of completion rate of employees conducting
their annual compliance training;
- Number of whistleblowing alerts; and
- Number of employee discrimination complaints.
We encourage all employees, including temporary external staff, to report conduct that violates
our policies. Our whistleblower reporting tool is also available to external groups.
Whistleblower Reporting Tool and Policy
SAP recognises the importance and encourages the reporting of potential misconduct or a
potential improper state of affairs relating to the Company. To foster the goal that every SAP
employee worldwide can be heard and speak out without fear and retaliation, we have
established a Global Ombuds Office which operates as an informal, independent, and
confidential channel on top of the formal complaint mechanisms in place, including our Speak
Out whistleblower reporting tool.
Speak Out at SAP is SAP’s independently hosted whistleblower reporting tool, through which
any matter or concern can be reported easily, and, if desired, anonymously. The tool is available
24 hours a day, seven days a week, both internally to SAP employees and externally to
concerned parties, including customers, suppliers, and partners. The tool is managed by SAP.
Reports may be submitted either directly by the reporter through the Internet based portal, or by
phone with local language support across the globe to maximise accessibility for reporters. In all
cases, SAP continues to maintain a strict non-retaliation policy.
Through this tool, we encourage all employees, including temporary external staff, to report
conduct that violates our policies. Beyond Speak Out at SAP, we provide further reporting
channels, including the internal ticketed system, a postal address for written submissions, asDocusign Envelope ID: 7A3971C2-5628-4D7D-A6FF-CAF016711E2B