The article 31-bis of Ley Orgánica 5/2010, later amended by Ley Orgánica 1/2015, introduced the Corporate Criminal Liability for Companies.
In accordance with above legal provisions, a legal entity may be criminally liable for a crime committed in its name or on its behalf, with direct or indirect profit, by its directors, managers or by anyone while subject to the authority of persons mentioned above.
Each Company can be held liable and consequently subject to monetary penalties and/or prohibitory measures, seriously affecting the business activity.
SAP gained a global reputation for probity and integrity, which has been a cornerstone of its success in business; the effective corporate governance is fundamental for achieving company’s objectives and increasing its value. Therefore, SAP España adopted a Compliance Organizational and Management Model which is a fundamental requirement to exclude its corporate criminal liability pursuant to article 31-bis of Ley Orgánica 1/2015 and is an essential part of the Local Compliance Management System.
In addition, SAP appointed Compliance Officers to supervise the functioning and the performance of the Model and other applicable policies. Compliance Officers must be informed of any violations of the Model and for this reason any violations can be communicated using the appropriate e-mail address
sap_spain_compliance@sap.com.
Such reports will be maintained with confidentiality and in accordance with applicable data protection law to the greatest extent practical.
