Ethics and compliance

SAP is committed to the highest standards of ethical business.
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Winning the right way

SAP strives to ensure that business success is built on integrity, following both the spirit and the letter of the law in all the markets in which we operate. Our culture of ethics and compliance is shaped by strong leadership on ethical business, supported by policies, training and a global network of field compliance officers.

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Vivianne Gordon-Pullar, SAP Group Chief Compliance Officer, speaks on the importance of doing business with integrity and the role of the Office of Ethics & Compliance.

Office of Ethics & Compliance

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Teaching prevention

Fostering a strong culture of ethical business, SAP actively and continuously provides employees, partners and suppliers with clear and comprehensive guidance on our ethics and compliance standards; via our codes of conduct, policies, and due diligence processes—as well as continuous advice, communication, and training.

Identifying concerns

At SAP, all employees have equal responsibility for upholding our standards of ethical business. We encourage them to feel empowered to voice their concerns about any situation without fear of personal retribution. We equally encourage those who do business with us to speak out. Reports about any suspected issues can be made confidentially, both through our network of field and people compliance officers and anonymously using our online reporting tool, Speak Out at SAP.*

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Addressing issues

Reported concerns are only shared with the relevant SAP department, for assessment and next steps. For instance, matters of compliance relating to potential bribery, corruption, or fraud are investigated by a dedicated team within our Office of Ethics & Compliance. Appropriate measures are taken to address any parties— employees, partners, or suppliers—found to have breached our codes of conduct.

We also actively identify lessons learned from audits, investigations, data analytics, and industry best practices to continuously strengthen the elements of our compliance management system.

Our key commitments

Learn more about our key commitments

The Office of Ethics & Compliance (OEC) provides clear policies and training to help prevent and address risks such as bribery, corruption, and fraud. It also fosters a culture of ethical leadership through a global network of field compliance officers who provide hands-on guidance to the business worldwide.

Our Code is a cornerstone in SAP’s commitment to the highest standards of ethical business. It guides all SAP employees in fulfilling our purpose and promise with integrity across our ecosystem.

Speak Out  is a confidential reporting tool that allows anyone in the SAP ecosystem—including employees, customers, partners—to report any potential violations relating to compliance, the law, or regulations. All submissions and identities are confidential to the greatest extent practical (based on the need to take further steps).

You can report any concerns using Speak Out at SAP, anonymously should you wish. You may also raise a concern by directly approaching the responsible department (such as the Office of Ethics & Compliance or the Global People Compliance Office), or through third-party channels according to the EU Whistleblower Directive (2019/1937).

SAP does not tolerate any threatened or actual retaliation toward individuals who speak up and reporting potential noncompliance in good faith.

 

If you believe you have been or are being subjected to retaliation for raising a concern, please report via Speak Out at SAP.

 

Anyone reporting a concern is subject to the protections granted by the EU Whistleblower Directive (2019/1937) on the protection of persons who report breaches of EU law, insofar as the requirements of the directive or of national implementations thereof apply.

*Speak Out at SAP is a comprehensive and confidential online reporting (whistleblower) tool provided by EQS. It allows for SAP employees as well as persons external to SAP to report concerns of non-compliance related to the Global Code of Ethics & Business Conduct and/or any law or regulation. The tool is managed by the Office of Ethics & Compliance (OEC) and reported concerns outside of OEC’s scope are shared only with the relevant SAP department for assessment and next steps.