SAP Global AI Ethics Policy
SAP Global Artificial Intelligence (AI) Ethics
Policy
Version Number: 3.0
Effective Date: June 15, 2026
Document Classification: Public
Policy
Version Number: 3.0
Effective Date: June 15, 2026
Document Classification: Public
SAP Global Artificial Intelligence (AI) Ethics Policy
Version 3.0, June 15, 2026
Document Classification: PUBLIC
The online version of this document is the officially released version. Any copies or printouts are not controlled.
© 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 / 18
Table of Contents
1. Introduction .................................................................................................................................................... 3
2. Purpose and Objectives ........................................................................................................................... 3
3. Scope .................................................................................................................................................................. 3
3.1. Internal Context .................................................................................................................................................................................... 3
3.2. External Context................................................................................................................................................................................... 4
4. AI Ethics Principles at SAP ...................................................................................................................... 4
4.1. Principle 1: Proportionality ........................................................................................................................................................... 5
4.2. Principle 2: Safety and Security ................................................................................................................................................. 6
4.3. Principle 3: Fairness and Non-Discrimination .................................................................................................................. 6
4.4. Principle 4: Sustainability ............................................................................................................................................................... 7
4.5. Principle 5: Right to Privacy and Data Protection ......................................................................................................... 7
4.6. Principle 6: Human Oversight and Determination ........................................................................................................ 8
4.7. Principle 7: Transparency and Explainability................................................................................................................... 9
4.8. Principle 8: Responsibility and Accountability ............................................................................................................ 10
4.9. Principle 9: Awareness and Literacy ................................................................................................................................... 10
4.10. Principle 10: Multi-Stakeholder and Adaptive Governance and Collaboration .................................. 11
5. AI Ethics Governance ............................................................................................................................... 11
5.1. AI Ethics Governance Bodies ................................................................................................................................................... 11
5.2. AI Ethics Use Case Impact Assessment ............................................................................................................................ 12
5.3. Feedback, Incident Management, and Corrective Measures ............................................................................ 13
6. Supporting Links and Documents ..................................................................................................... 13
7. Terms and Definitions.............................................................................................................................. 14
Version 3.0, June 15, 2026
Document Classification: PUBLIC
The online version of this document is the officially released version. Any copies or printouts are not controlled.
© 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 / 18
Table of Contents
1. Introduction .................................................................................................................................................... 3
2. Purpose and Objectives ........................................................................................................................... 3
3. Scope .................................................................................................................................................................. 3
3.1. Internal Context .................................................................................................................................................................................... 3
3.2. External Context................................................................................................................................................................................... 4
4. AI Ethics Principles at SAP ...................................................................................................................... 4
4.1. Principle 1: Proportionality ........................................................................................................................................................... 5
4.2. Principle 2: Safety and Security ................................................................................................................................................. 6
4.3. Principle 3: Fairness and Non-Discrimination .................................................................................................................. 6
4.4. Principle 4: Sustainability ............................................................................................................................................................... 7
4.5. Principle 5: Right to Privacy and Data Protection ......................................................................................................... 7
4.6. Principle 6: Human Oversight and Determination ........................................................................................................ 8
4.7. Principle 7: Transparency and Explainability................................................................................................................... 9
4.8. Principle 8: Responsibility and Accountability ............................................................................................................ 10
4.9. Principle 9: Awareness and Literacy ................................................................................................................................... 10
4.10. Principle 10: Multi-Stakeholder and Adaptive Governance and Collaboration .................................. 11
5. AI Ethics Governance ............................................................................................................................... 11
5.1. AI Ethics Governance Bodies ................................................................................................................................................... 11
5.2. AI Ethics Use Case Impact Assessment ............................................................................................................................ 12
5.3. Feedback, Incident Management, and Corrective Measures ............................................................................ 13
6. Supporting Links and Documents ..................................................................................................... 13
7. Terms and Definitions.............................................................................................................................. 14
SAP Global Artificial Intelligence (AI) Ethics Policy
Version 3.0, June 15, 2026
Document Classification: PUBLIC
The online version of this document is the officially released version. Any copies or printouts are not controlled.
© 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. 3 / 18
1. Introduction
As Artificial Intelligence (AI) adoption grows, companies must be able to manage both risks and opportunities
across the value chain. To ensure Responsible AI, AI Systems must be ethical, technically robust, and lawful,
augmenting human capabilities while minimizing risks of Harm and misuse. Extending beyond legal
requirements, this Policy demonstrates SAP’s commitment to the ethical development, deployment, sale, and
use of AI Systems. Ethical AI builds Customer and stakeholder trust, accelerates AI adoption, reduces legal
and operational risk, supports regulatory readiness, and creates a competitive advantage that strengthens
long-term growth and innovation.
Fundamental to SAP’s AI Ethics approach is the company’s commitment to upholding and supporting human
rights, as articulated in SAP’s Global Human Rights Commitment Statement and in alignment with the
Universal Declaration of Human Rights. When the Global AI Ethics Policy was last updated, the principles
were adapted from UNESCO’s Recommendation on the Ethics of Artificial Intelligence. Building on this
foundation, this version of the Policy reflects technological advancements, market research, regulatory
developments, and other frameworks. Notably, input from the NIST AI Risk Management Framework, OECD AI
Principles, the EU Artificial Intelligence Act, ISO/IEC 42001, and others was considered for this Policy. SAP’s
principles, Policy, and processes will continue to evolve accordingly. SAP’s AI Ethics principles are:
1. Proportionality
2. Safety and Security
3. Fairness and Non-Discrimination
4. Sustainability
5. Right to Privacy and Data Protection
6. Human Oversight and Determination
7. Transparency and Explainability
8. Responsibility and Accountability
9. Awareness and Literacy
10. Multi-stakeholder and Adaptive Governance and Collaboration
2. Purpose and Objectives
SAP believes that AI presents vast opportunities for businesses, governments, and society. However, AI may
also create economic, political, and societal challenges, depending on how it is implemented and used. This
Policy therefore governs the development, deployment, sale, and use of AI Systems at SAP, by defining clear
rules of ethics complementing national and international rules and standards. In building ethical AI, SAP
fosters sustainable and human-centered innovation, creates better products, and deepens stakeholder trust
by designing Solutions that respect human rights, augment human capabilities, and remain under Human
Oversight. To learn more about the operationalization of the Policy, see the material published on
Responsible AI | SAP.
3. Scope
3.1. Internal Context
This Policy applies to SAP Group employees and all Actors (that is, SAP employees who play an active role in
any phase of the AI System Lifecycle) and to AI Systems developed by:
• SAP, whether commercialized or not;
Version 3.0, June 15, 2026
Document Classification: PUBLIC
The online version of this document is the officially released version. Any copies or printouts are not controlled.
© 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. 3 / 18
1. Introduction
As Artificial Intelligence (AI) adoption grows, companies must be able to manage both risks and opportunities
across the value chain. To ensure Responsible AI, AI Systems must be ethical, technically robust, and lawful,
augmenting human capabilities while minimizing risks of Harm and misuse. Extending beyond legal
requirements, this Policy demonstrates SAP’s commitment to the ethical development, deployment, sale, and
use of AI Systems. Ethical AI builds Customer and stakeholder trust, accelerates AI adoption, reduces legal
and operational risk, supports regulatory readiness, and creates a competitive advantage that strengthens
long-term growth and innovation.
Fundamental to SAP’s AI Ethics approach is the company’s commitment to upholding and supporting human
rights, as articulated in SAP’s Global Human Rights Commitment Statement and in alignment with the
Universal Declaration of Human Rights. When the Global AI Ethics Policy was last updated, the principles
were adapted from UNESCO’s Recommendation on the Ethics of Artificial Intelligence. Building on this
foundation, this version of the Policy reflects technological advancements, market research, regulatory
developments, and other frameworks. Notably, input from the NIST AI Risk Management Framework, OECD AI
Principles, the EU Artificial Intelligence Act, ISO/IEC 42001, and others was considered for this Policy. SAP’s
principles, Policy, and processes will continue to evolve accordingly. SAP’s AI Ethics principles are:
1. Proportionality
2. Safety and Security
3. Fairness and Non-Discrimination
4. Sustainability
5. Right to Privacy and Data Protection
6. Human Oversight and Determination
7. Transparency and Explainability
8. Responsibility and Accountability
9. Awareness and Literacy
10. Multi-stakeholder and Adaptive Governance and Collaboration
2. Purpose and Objectives
SAP believes that AI presents vast opportunities for businesses, governments, and society. However, AI may
also create economic, political, and societal challenges, depending on how it is implemented and used. This
Policy therefore governs the development, deployment, sale, and use of AI Systems at SAP, by defining clear
rules of ethics complementing national and international rules and standards. In building ethical AI, SAP
fosters sustainable and human-centered innovation, creates better products, and deepens stakeholder trust
by designing Solutions that respect human rights, augment human capabilities, and remain under Human
Oversight. To learn more about the operationalization of the Policy, see the material published on
Responsible AI | SAP.
3. Scope
3.1. Internal Context
This Policy applies to SAP Group employees and all Actors (that is, SAP employees who play an active role in
any phase of the AI System Lifecycle) and to AI Systems developed by:
• SAP, whether commercialized or not;
SAP Global Artificial Intelligence (AI) Ethics Policy
Version 3.0, June 15, 2026
Document Classification: PUBLIC
The online version of this document is the officially released version. Any copies or printouts are not controlled.
© 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. 4 / 18
• SAP Suppliers and embedded in SAP Solutions;
• SAP Suppliers and sold by SAP (such as Supplier-branded resellers or SAP-branded resellers);
and/or
• SAP Suppliers and used by SAP for internal purposes.
All SAP Group employees, regardless of their role in the AI System Lifecycle, must understand:
• Which ethical principles apply to AI Systems and how these principles are implemented, further
supported by internal enablement material;
• Governance processes for ethical AI Systems and Solutions;
• Feedback mechanisms for reporting non-compliance of the AI System to ethical principles.
If any member of the SAP Group has an individual AI Ethics policy, it must be adapted within a reasonable
time to comply with the effective version of this Policy. While this Policy is applicable to all SAP Group
companies, it does not override any applicable laws or regulations. If any requirement in this Policy conflicts
with any applicable law or regulation, such conflict should be reported to the AI Ethics office.
3.2. External Context
Acknowledging the role of external stakeholders in the AI System Lifecycle, different agreements may apply:
• Relevant Partners must adhere to SAP’s Partner Code of Conduct and are recommended to adhere
to this Policy. Endorsed Partners and partnerships through SAP Solution extensions must adhere to
this Policy and undergo SAP’s AI Ethics Assessment process.
• For information about obligations relevant to Suppliers, see SAP’s Supplier Code of Conduct.
• For information related to AI technologies licensed from third parties, see SAP’s AI Third Party Pass-
Through Terms.
SAP makes reasonable efforts to ensure that AI Systems delivered to Customers comply with the ethical
principles described in this Policy. However, Customers are solely responsible for using AI Systems within
intended purpose and in compliance with all laws and regulations including any applicable national or
sector-specific regulatory requirements. SAP has published AI Terms, which specify responsibilities and the
permitted and prohibited usage of AI Systems by Customers.
4. AI Ethics Principles at SAP
Any Actor involved in any phase of the AI System Lifecycle must ensure that AI Systems are designed,
developed, deployed, sold, or used in adherence with the AI Ethics principles specified in this Policy,
according to the scope of the Actor’s respective role and Responsibility. SAP’s level of control depends on
whether a component of the AI System is trained and/or developed by SAP or sourced from a Third Party.
The SAP AI Ethics Office and other governance bodies support product teams in finding measures to
implement the principles appropriately to the Use Case (see chapter 5).
The following principles can only provide the foundation for ethical AI when applied collectively and
appropriately to the Use Case–specific context. While separate chapters and requirements for each
principle are provided, the principles are interconnected and mutually reinforcing. Accordingly, some AI
Ethics requirements apply across multiple principles, as follows:
How the principles are implemented at SAP
• Compliance with SAP’s Global Development Policy (SAP internal) and SAP’s Product Standards (SAP
internal) must be ensured.
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• SAP Suppliers and embedded in SAP Solutions;
• SAP Suppliers and sold by SAP (such as Supplier-branded resellers or SAP-branded resellers);
and/or
• SAP Suppliers and used by SAP for internal purposes.
All SAP Group employees, regardless of their role in the AI System Lifecycle, must understand:
• Which ethical principles apply to AI Systems and how these principles are implemented, further
supported by internal enablement material;
• Governance processes for ethical AI Systems and Solutions;
• Feedback mechanisms for reporting non-compliance of the AI System to ethical principles.
If any member of the SAP Group has an individual AI Ethics policy, it must be adapted within a reasonable
time to comply with the effective version of this Policy. While this Policy is applicable to all SAP Group
companies, it does not override any applicable laws or regulations. If any requirement in this Policy conflicts
with any applicable law or regulation, such conflict should be reported to the AI Ethics office.
3.2. External Context
Acknowledging the role of external stakeholders in the AI System Lifecycle, different agreements may apply:
• Relevant Partners must adhere to SAP’s Partner Code of Conduct and are recommended to adhere
to this Policy. Endorsed Partners and partnerships through SAP Solution extensions must adhere to
this Policy and undergo SAP’s AI Ethics Assessment process.
• For information about obligations relevant to Suppliers, see SAP’s Supplier Code of Conduct.
• For information related to AI technologies licensed from third parties, see SAP’s AI Third Party Pass-
Through Terms.
SAP makes reasonable efforts to ensure that AI Systems delivered to Customers comply with the ethical
principles described in this Policy. However, Customers are solely responsible for using AI Systems within
intended purpose and in compliance with all laws and regulations including any applicable national or
sector-specific regulatory requirements. SAP has published AI Terms, which specify responsibilities and the
permitted and prohibited usage of AI Systems by Customers.
4. AI Ethics Principles at SAP
Any Actor involved in any phase of the AI System Lifecycle must ensure that AI Systems are designed,
developed, deployed, sold, or used in adherence with the AI Ethics principles specified in this Policy,
according to the scope of the Actor’s respective role and Responsibility. SAP’s level of control depends on
whether a component of the AI System is trained and/or developed by SAP or sourced from a Third Party.
The SAP AI Ethics Office and other governance bodies support product teams in finding measures to
implement the principles appropriately to the Use Case (see chapter 5).
The following principles can only provide the foundation for ethical AI when applied collectively and
appropriately to the Use Case–specific context. While separate chapters and requirements for each
principle are provided, the principles are interconnected and mutually reinforcing. Accordingly, some AI
Ethics requirements apply across multiple principles, as follows:
How the principles are implemented at SAP
• Compliance with SAP’s Global Development Policy (SAP internal) and SAP’s Product Standards (SAP
internal) must be ensured.
SAP Global Artificial Intelligence (AI) Ethics Policy
Version 3.0, June 15, 2026
Document Classification: PUBLIC
The online version of this document is the officially released version. Any copies or printouts are not controlled.
© 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. 5 / 18
• High data-quality is fundamental for SAP’s AI Systems, requiring that data is accurate, reliable, and
relevant to the context.
• AI Systems must be designed and developed with logging capabilities to support traceability,
monitoring, and accountability, while adhering to Data Protection and Privacy standards.
• AI Systems must be monitored and evaluated throughout the AI System Lifecycle to ensure ongoing
adherence to the principles listed in this Policy and to detect possible drifts as early as possible.
4.1. Principle 1: Proportionality
Proportional AI Systems must not exceed what is necessary to achieve their intended purpose and must be
used in a context-appropriate manner to minimize potential Harm. Human rights and fundamental freedoms
must be respected during all stages of the AI System Lifecycle.
How this principle is implemented at SAP
• Actors who develop an AI System define its purpose and tasks. The scope defined should match the
behavior and functionality of the deployed Solution.
• The context and environment of the AI System must be analyzed, and appropriate measures must be
taken to prevent misuse or unintended Harm.
• In addition, SAP defines a set of “red lines” along the categories of personal freedom and society. If
any of these are identified, the continued development, deployment, sale, and use of the AI System is
prohibited (for more information, see chapter 4.1.1. and 4.1.2.).
• As part of SAP’s AI Ethics Use Case impact assessment process, impact classification mechanisms
and measures to mitigate Harm shall be defined to ensure that human rights and fundamental
freedoms are safeguarded.
4.1.1. Personal Freedom
• AI Systems must not be developed, deployed, sold, or used for human surveillance to target
individuals or groups—whether by biometrics, which includes facial and emotion recognition, or by
other methods analyzing identifiable features.
• AI Systems must not be developed, deployed, sold, or used for discrimination against individuals or
groups of people, as described in SAP’s Global Code of Ethics and Business Conduct. This also
includes denying individuals or groups of people equal access to AI’s benefits and opportunities.
• AI Systems must not be developed, deployed, sold, or used to deanonymize previously anonymized
data.
4.1.2. Society
• AI Systems must not be designed to have harmful impacts on users or Affected Individuals.
• AI Systems must not be developed, deployed, sold, or used with the goal of deceiving or unfairly
manipulating individuals or groups.
• AI Systems must not be developed, deployed, sold, or used to undermine public debates or
electoral systems or processes.
• AI Systems must not be developed, deployed, sold, or used with the goal of morally assessing or
classifying individuals’ social behavior, including known or predicted personal characteristics, such as
in social scoring.
• The context and environment of the AI System must be analyzed, and appropriate measures
implemented to prevent misuse or unintended Harm to humans.
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• High data-quality is fundamental for SAP’s AI Systems, requiring that data is accurate, reliable, and
relevant to the context.
• AI Systems must be designed and developed with logging capabilities to support traceability,
monitoring, and accountability, while adhering to Data Protection and Privacy standards.
• AI Systems must be monitored and evaluated throughout the AI System Lifecycle to ensure ongoing
adherence to the principles listed in this Policy and to detect possible drifts as early as possible.
4.1. Principle 1: Proportionality
Proportional AI Systems must not exceed what is necessary to achieve their intended purpose and must be
used in a context-appropriate manner to minimize potential Harm. Human rights and fundamental freedoms
must be respected during all stages of the AI System Lifecycle.
How this principle is implemented at SAP
• Actors who develop an AI System define its purpose and tasks. The scope defined should match the
behavior and functionality of the deployed Solution.
• The context and environment of the AI System must be analyzed, and appropriate measures must be
taken to prevent misuse or unintended Harm.
• In addition, SAP defines a set of “red lines” along the categories of personal freedom and society. If
any of these are identified, the continued development, deployment, sale, and use of the AI System is
prohibited (for more information, see chapter 4.1.1. and 4.1.2.).
• As part of SAP’s AI Ethics Use Case impact assessment process, impact classification mechanisms
and measures to mitigate Harm shall be defined to ensure that human rights and fundamental
freedoms are safeguarded.
4.1.1. Personal Freedom
• AI Systems must not be developed, deployed, sold, or used for human surveillance to target
individuals or groups—whether by biometrics, which includes facial and emotion recognition, or by
other methods analyzing identifiable features.
• AI Systems must not be developed, deployed, sold, or used for discrimination against individuals or
groups of people, as described in SAP’s Global Code of Ethics and Business Conduct. This also
includes denying individuals or groups of people equal access to AI’s benefits and opportunities.
• AI Systems must not be developed, deployed, sold, or used to deanonymize previously anonymized
data.
4.1.2. Society
• AI Systems must not be designed to have harmful impacts on users or Affected Individuals.
• AI Systems must not be developed, deployed, sold, or used with the goal of deceiving or unfairly
manipulating individuals or groups.
• AI Systems must not be developed, deployed, sold, or used to undermine public debates or
electoral systems or processes.
• AI Systems must not be developed, deployed, sold, or used with the goal of morally assessing or
classifying individuals’ social behavior, including known or predicted personal characteristics, such as
in social scoring.
• The context and environment of the AI System must be analyzed, and appropriate measures
implemented to prevent misuse or unintended Harm to humans.