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(32) German Code of Corporate Governance

The German federal government published the German Code of Corporate Governance in February 2002 and introduced a commission that amends the Code from time to time. The Code contains statutory requirements and a number of recommendations and suggestions. Only the legal requirements are binding for German companies. With regard to the recommendations, the German Stock Corporation Act, section 161, requires that every year listed companies publicly state the extent to which they have implemented them. Companies can deviate from the suggestions without having to make any public statements.

In 2016 and 2015, our Executive Board and Supervisory Board issued the required declarations of implementation. The declaration for 2016 was issued on October 29, 2016. These statements are available on our Web site: www.sap.com/corporate-en/investors/governance.

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