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Business Conduct

Championing Excellence in Business Conduct

In our business, trust is everything. We know that to engage with SAP fully, our customers must first trust that our business practices adhere to the highest standards of compliance and integrity.

All too often we see the impact of poor business conduct in the wider business community. Corrupt and unethical practices irreparably damage brand reputations and lead to punitive financial penalties for the organizations involved. Such behavior undermines the rule of international law and is also linked to poverty and irreversible environmental damage across the globe.

New fraud and corruption schemes are discovered all the time in an ever-changing business environment. Therefore, SAP must constantly adapt our approach to compliance to incorporate new best practices and meet new challenges.

Establishing Clear and Comprehensive Standards

We have developed a compliance management system for enforcing ethical business conduct. This includes detailed policies and procedures to ensure that SAP does business the right way.

Audited regularly, the system encompasses all aspects of compliance management. From the analysis of compliance risks and defining objectives to running compliance programs as well as ongoing monitoring, this comprehensive framework enables us to maintain a responsible compliance organization.

Fostering a Culture of Compliance

To help foster a corporate culture where compliance is taken seriously, we needed to establish a common understanding of what we mean by compliance. We did this by creating a code of business conduct that summarizes our standards. The code contains guidelines for all SAP employees worldwide as they perform their daily work.

Approved by the Executive Board at SAP, the code sets the standard for our dealings with customers, partners, competitors, and vendors. It is adapted locally and translated into local languages.

Key areas covered by the code of business conduct include:

  • Prohibition of bribery and corruption in all its forms, including facilitation or “grease payments”
  • Gifts and business entertainment limits
  • Full, fair, and accurate accounting
  • Conflicts of interest
  • Confidentiality
  • Anti-competitive practices
  • Data protection and privacy rights

Setting High Expectations Across All Business Activities

SAP has established a number of policies to maintain the highest standards of business conduct including in the following areas:

  • Regulation of the appointment and remuneration of sales agents
  • Charitable and political donations
  • Global intellectual property
  • Group accounting and revenue recognition
  • Segregation of duty
  • Export control and sanctions laws
  • Data protection and privacy

Additional policies or commitments related to sustainability are under the responsibility of the respective lines of business and can be found at sap.com.

Providing Comprehensive Training

A code of business conduct is only effective if everyone knows about it. That is why we strive to make sure all of our employees receive full training on the standards that we expect.

In 2016, we introduced mandatory online training for all employees worldwide. In total, more than 79,200 employees (93% of SAP staff) received this training. Here is a full breakdown of our training activities is presented in the table below.

Region Training sessions completed by employees, in % Training sessions completed by employees, in headcount
Americas 93 22,882
APJ 89 20,778
EMEA 96 35,578

Our training program covers a wide range of topics around business conduct. These include guidelines on anti-corruption, competition law, governance for customer commitments, intellectual property, and information security.

E-learning modules are available in nine different languages. In addition, our legal compliance and integrity office also holds classroom training sessions. Employees from across the SAP organization take part, from customer-facing staff to individuals in supporting roles such as corporate affairs and marketing. In addition, general compliance information on relevant policies is included in the onboarding sessions for new hired run by our HR organization.

Communicating Our Standards

Quarterly newsletters provide employees with information on a range of compliance-related topics. These communications include details of cases that have recently been highlighted in the media as well as presenting hypothetical scenarios that provide people with opportunities for self-reflection. In addition, the newsletters provide links to other relevant sources of information such as our whistleblower reporting system, legal compliance and integrity office, corporate audit department, and SAP global policies.

We ask business ethics and compliance-related questions in our annual People Survey. Through the SAP Corporate Portal, we run company-wide polls on a variety of compliance-related questions throughout the year. In addition, employees can use the portal at any time for quick and easy access to all global policies along with guidelines and additional information.

Colleagues within the legal compliance and integrity office carry out ongoing programs of calls and meetings to raise awareness of business conduct issues throughout the organization. Meanwhile, regular e-mail communications with subsidiaries and the availability of information in local languages help to promote leading standards of business conduct across every part of the SAP ecosystem.

Analyzing Compliance Risk

At SAP, we want to address issues before they become problems. For this reason, we believe that analysis of compliance risk is key to maintaining the highest standards of business conduct.

On an ongoing basis, we review SAP business units for potential bribery or corruption. For example, in 2016, we collected quantitative data about 154 SAP entities supporting 142 countries. This data includes revenue information, number of employees, percentage of public sector business, number of fraud allegations or incidents, changes or updates to relevant laws, and other quantitative information. Based on this information and management input, we determine a risk ranking for each country.

Our assessment also helps us create a general risk profile for subsidiary locations. Through analysis of our quantitative data, we determine which countries require our highest attention.

Our legal compliance and integrity office works closely with our global governance, risk, and compliance organization to identify areas where a risk assessment is needed. We then drive compliance mitigation programs if necessary. Generally, we find that our primary compliance risks are related to corruption, antitrust issues, export controls, and intellectual property. For more information, see our Risk Report section.

Enforcing Policies

SAP is committed to ensuring that our compliance policies are strictly enforced, and that any infringements are quickly flagged and acted upon. To achieve this, we have built an effective global network of compliance professionals who act as our ambassadors at country level for business conduct.

The legal compliance and integrity office oversees the development of our code of business conduct, as well as all other related policies and our anti-corruption program. Global compliance officers are based at SAP headquarters and in our most important markets, especially where there are local language needs. In addition, compliance officers at local subsidiaries assess issues and escalate them to the global level if necessary.

In addition to making regular reports to the CFO and the Executive Board, the chief global compliance officer provides at the least annual reports to the audit committee of the Supervisory Board. Matters of significance are brought to the attention of the Executive Board and the audit committee of the Supervisory Board when required.

Employees at all levels of the organization are required to disclose conflicts of interest to the legal compliance and integrity office. Disclosures are then followed up with guidance or mitigation if necessary.

Facilitating Reporting and Remediation

If employees are concerned that our code of business conduct has been breached, or if they need advice on a compliance issue, they can access support in a number of ways. They can:

  • Call our governance hotline at +49 6227 7-40022
  • E-mail the legal compliance and integrity office at global-compliance-office@sap.com
  • Contact with local compliance officers via e-mail or telephone
  • Use the anonymous online whistleblower tool

Employees can find information on how to report compliance issues in SAP Corporate Portal, and new hires are informed of reporting channels during the new hire process. External stakeholders without access to SAP Corporate Portal can find the hotline number and e-mail address on SAP.com. In addition, reporting channels are described in our codes of conduct for partners and suppliers. Most of these reporting mechanisms are available 24x7, and concerns are treated as confidentially as possible in light of subsequent investigation.

All concerns are investigated, and remedial action is taken if necessary. This may include termination of employment.

Taking a Proactive Stance Against Corruption

SAP is proactively working in collaboration with the wider business community to fight against corruption and the negative impacts it creates. SAP is a member of the German chapter of Transparency International, a non-profit, non-partisan organization that combats corruption in government and international business and development.

In addition, we are active in the Alliance for Integrity (AfIn). AfIn is a business-driven, multistakeholder initiative promoting economic integrity and compliance in business. It was initiated by a number of multinational companies, business associations, the German Federal Ministry for Economic Cooperation and Development (BMZ), the Society for International Cooperation (GIZ), the German Global Compact Network and sequa, a non-profit development organization. The focus of the initiative is on implementing collective action on the ground.

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