Is SAP ethical?

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LGBTQ+ policies Confirmed You decide

SAP adds gender-transition care to employee benefits

SAP announced new benefits including gender-transition care for transgender employees.

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fortune.com
SAP Announces New Benefits for Transgender Employees
What exactly does that mean? Well, SAP already offered several basic medical benefits to transgender employees, including mental health counseling for those in transition and coverage for sex reassignment surgery.

Community investment Confirmed In favor

SAP donates €250,000 to Gaza humanitarian aid

SAP donates €250,000 to Magen David Adom and Alon and Ella Association for immediate needs of Gaza border settlement families.

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timesofisrael.com
SAP has also committed to donate €250,000 to the Magen David Adom (MDA) and the Alon and Ella Association, which caters to the immediate needs of families from the Gaza border settlements.

Corporate conduct Confirmed Against

SAP under DOJ investigation for price-fixing

SAP is reportedly under investigation by the DOJ for price-fixing and stock down.

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finance.yahoo.com
SAP Reportedly Under Investigation by DOJ for Price-Fixing, Stock Down

Corporate conduct Settlement Against

SAP settles bribery charges with $220m payment

SAP has agreed to pay more than $220m to settle global bribery charges involving government officials.

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apnews.com
The Justice Department’s statement commended SAP for cooperating with the department’s investigation, taking steps to uncover the root causes of the bribery, and boosting resources for a restructured ethics and compliance office.
German software giant SAP fined more than $220M to resolve US bribery allegations | AP News
finance.yahoo.com
SAP also reached a related civil settlement with the U.S. Securities and Exchange Commission to resolve charges over similar alleged bribery schemes in Azerbaijan, Ghana, Kenya, Malawi and Tanzania, as well as Indonesia and South Africa. The company "has accepted responsibility for corrupt practices that hurt honest businesses engaging in global commerce," U.S. Attorney Jessica Aber in the Eastern District of Virginia said in a statement.
bbc.com
Software firm SAP to pay $220m over bribery charges
Global software giant SAP has agreed to pay more than $220m (£172m) to settle bribery charges involving government officials around the world.
sec.gov
“Our order holds SAP accountable for misconduct that spanned seven jurisdictions and persisted for several years and serves as a stark reminder of the need for global companies to be attuned to both the risks of their business and the need to maintain adequate entity-level controls over all their subsidiaries,” said Charles E.

Corporate conduct Ruling Against

SAP paid more than $230 million to settle bribery charges

SAP, the $192 billion German enterprise tech company, will pay more than $230 million to settle investigations into worldwide "recidivist" foreign bribery practices, U.S. authorities announced Wednesday.

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apnews.com
German software giant SAP will pay more than $220 million in fines to resolve U.S. bribery allegations involving payments to foreign government officials, the Justice Department said Wednesday.
According to court documents cited by the Justice Department, SAP and unnamed co-conspirators provided bribes and other valuable enticements to South African and Indonesian foreign officials. The company delivered gifts to officials in the form of cash payments, political contributions, electronic transfers, and luxury goods purchased during shopping trips.
German software giant SAP fined more than $220M to resolve US bribery allegations | AP News
clsbluesky.law.columbia.edu
According to the resolutions, from 2013 to 2018, SAP made improper payments to officials at state-owned entities in South Africa and Indonesia to secure and retain software and professional services contracts with those entities.
finance.yahoo.com
Authorities said the alleged bribery schemes spanned from 2013 to 2022, and involved falsifying SAP's books and records so the bribes would appear to be legitimate business expenses.
SAP also reached a related civil settlement with the U.S. Securities and Exchange Commission to resolve charges over similar alleged bribery schemes in Azerbaijan, Ghana, Kenya, Malawi and Tanzania, as well as Indonesia and South Africa. The company "has accepted responsibility for corrupt practices that hurt honest businesses engaging in global commerce," U.S. Attorney Jessica Aber in the Eastern District of Virginia said in a statement.
cnbc.com
SAP, the $192 billion German enterprise tech company, will pay more than $230 million to settle investigations into worldwide "recidivist" foreign bribery practices, U.S. authorities announced Wednesday.
The settlement has been anticipated since at least June, when SAP set aside roughly $186 million for a potential settlement or fines related to bribery probes.
The company will enter into a three-year deferred prosecution agreement with federal prosecutors, who accused SAP of violating the Foreign Corrupt Practices Act to allegedly bribe government officials in Indonesia and South Africa, the Justice Department said.
SAP and its employees bribed government officials in those countries with cash, political donations, luxury goods and shopping sprees, the Justice Department said in a release.
Concurrently, the company will also pay a $98 million disgorgement to the Securities and Exchange Commission, which alleged that SAP improperly recorded the bribes paid to officials in Azerbaijan, Ghana, Indonesia, Malawi, Kenya and South Africa on its own books as "legitimate business expenses."
independent.co.uk
German software giant SAP will pay more than $220 million in fines to resolve U.S. bribery allegations involving payments to foreign government officials, the Justice Department said Wednesday.
German software giant SAP will pay more than $220 million in fines to resolve U.S. bribery allegations involving payments to foreign government officials
German software giant SAP fined more than $220M to resolve US bribery allegations | The Independent
sec.gov
SAP SE agreed to a settled C&D order for violating the anti-bribery, recordkeeping, and internal accounting controls provisions of the FCPA and to pay $98 million in disgorgement and PJI (to be offset by up to $59 million to be paid to South African authorities).
SAP SE - The software manufacturer agreed to give up $3.7 million in sales profits to settle SEC charges that it violated the FCPA when its deficient internal controls enabled an executive to pay bribes to procure business in Panama.
sec.gov
In January 2024, following comprehensive and exhaustive investigations, dialogue, and corresponding remediation activities, SAP entered into a final settlement agreement with the U.S. SEC and the U.S. DOJ, as well as with local authorities and parties in South Africa, to resolve the criminal and civil claims fully and finally against SAP. Under this agreement, SAP has been required to make payments amounting to €207 million and will continue to enhance its compliance program, including related internal controls, policies, and procedures, and report to and cooperate with relevant regulators.
Under this agreement, SAP has been required to make payments amounting to €207 million and will continue to enhance its compliance program, including related internal controls, policies, and procedures, and report to and cooperate with relevant regulators.
sec.gov
Several SOCAR officials received gifts totaling approximately $3,000, well above SAP’s gift limit of $30.
On December 23, 2014, SAP South Africa closed on a $4.4 million deal with South African state-owned rail and logistics company, Transnet, with an intermediary third party (“SA Intermediary 1”) purportedly acting as a BDP.
SAP South Africa also paid bribes in order to obtain a December 29, 2015 contract with the City of Johannesburg valued at $13.16 million for a license consolidation.
Chat messages between the SAP South Africa local account executive and a City of Johannesburg employee corroborate that the local account executive directed, and the business partner made, the improper payment.
In addition to these cash payments, SAP South Africa paid for trips to New York for government officials in May and September 2015, including the officials’ meals and golf outings on the trips.
SAP Indonesia paid the bribes to obtain a March 23, 2018 contract with BP3TI valued at $268,135.
In November 2016, SAP South Africa closed a deal with Eskom, a state-owned entity and the largest producer of electricity in South Africa, to renew software licenses for approximately $28.58 million.
From at least December 2014 through December 2018, SAP employed third-party intermediaries and consultants in various schemes to make improper payments to government officials in order to obtain and retain business in South Africa, Greater Africa (Malawi, Kenya, Tanzania, and Ghana), and Indonesia.
In August 2016, an SAP South Africa account executive directed one of the partners to make an improper ZAR 2.2 million (approximately $120,000) payment to an account for an entity known to be involved with corrupt activities.
Emails indicate that SAP Africa provided GA Intermediary 1 with the specifications needed for GNPC to justify sole sourcing the contract, and then the intermediary passed those specifications to GNPC in order to win the tender.
SAP South Africa retained multiple third party consultants in South Africa to offer or pay bribes to government officials or intermediaries in order to obtain contracts with public sector customers.
The Securities and Exchange Commission (“Commission”) deems it appropriate and in the public interest that cease-and-desist proceedings be, and hereby are, instituted pursuant to Section 21C of the Securities Exchange Act of 1934 (“Exchange Act”), against SAP SE (“SAP” or “Respondent”). II. In anticipation of the institution of these proceedings, Respondent has submitted an Offer of Settlement (the “Offer”) which the Commission has determined to accept.
Internally, SAP South Africa set aside several million dollars from this renewal fee to pay SA Intermediary 3, a purported IT consultant on the Eskom project.
sec.gov
The Securities and Exchange Commission today announced charges against global software company SAP SE for violations of the Foreign Corrupt Practices Act (FCPA) arising out of bribery schemes in South Africa, Malawi, Kenya, Tanzania, Ghana, Indonesia, and Azerbaijan. The company agreed to monetary sanctions of nearly $100 million in disgorgement and prejudgment interest to settle the SEC’s charges.
In its parallel case, SAP agreed to pay the DOJ a $118.8 million criminal fine and to a forfeiture of approximately $103 million, of which $85 million will be satisfied by the company’s payment of disgorgement pursuant to the SEC’s order.

Corporate conduct Settlement Against

SAP agreed to give up $3.7 million in sales profits to settle SEC charges that it violated the FCPA when its deficient internal controls enabled an executive to pay bribes to procure business in Panama

SAP SE - The software manufacturer agreed to give up $3.7 million in sales profits to settle SEC charges that it violated the FCPA when its deficient internal controls enabled an executive to pay bribes to procure business in Panama.

4 sourcesRead sources
clsbluesky.law.columbia.edu
Here, SAP did not have a prior DOJ FCPA resolution, but did have “a non-prosecution agreement from 2021 with the department’s National Security Division, as well as administrative agreements with the Departments of Commerce and the Treasury relating to export law violations, and a resolution in 2016 with the SEC concerning alleged [i.e., neither admit nor deny] FCPA violations in Panama.” DOJ therefore calibrated the prior misconduct and resolutions to start much closer to the low end of the fine range than if there were a prior DOJ FCPA resolution.
To resolve the matter, SAP entered into an administrative order with the SEC requiring SAP to pay approximately $85 million in disgorgement and $13 million in prejudgment interest, but received an offset of approximately $60 million for payments “made or to be made” to South African authorities in connection with a parallel enforcement action there.
sec.gov
SAP SE - The software manufacturer agreed to give up $3.7 million in sales profits to settle SEC charges that it violated the FCPA when its deficient internal controls enabled an executive to pay bribes to procure business in Panama.
sec.gov
“SAP’s internal controls failed to flag Garcia’s misconduct as he easily falsified internal approval forms and disguised his bribes as discounts,” said Kara Brockmeyer, Chief of the SEC Enforcement Division’s FCPA Unit.
An SEC investigation found that SAP’s deficient internal controls allowed a former SAP executive to pay $145,000 in bribes to a senior Panamanian government official and offer bribes to two others in exchange for lucrative sales contracts.
The Securities and Exchange Commission today announced that software manufacturer SAP SE has agreed to give up $3.7 million in sales profits to settle charges that it violated the Foreign Corrupt Practices Act (FCPA) when procuring business in Panama.
The bribery scheme involved providing large discounts of up to 82 percent to SAP’s Panamanian partner, who used the excessive discounts to create a slush fund out of which to pay bribes to Panamanian officials on Garcia’s behalf so SAP could sell software.
Without admitting or denying the findings, SAP consented to the entry of the cease-and-desist order and agreed to pay disgorgement of $3.7 million in profits from SAP’s software sales to the Panamanian government plus prejudgment interest of $188,896.
sec.gov
SAP agreed to cease and desist from committing or causing any violations of these provisions and to pay disgorgement of $85 million plus prejudgment interest of more than $13.4 million, totaling more than $98 million, which will be offset by up to $59 million paid by SAP to the South African government in connection with its parallel investigations into the same conduct.
In 2016, the SEC charged SAP with books and records and internal accounting controls violations in connection with a bribery scheme in Panama.

Ukraine & Russia Confirmed You decide

SAP donates Ariba solutions to NGO supporting Ukraine healthcare

SAP donated Ariba solutions to an NGO working with Ukraine's State Enterprise Medical Procurement to enable faster purchasing of medical goods for the Ministry of Healthcare.

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business-humanrights.org
...We recently donated SAP Ariba solutions to an NGO working with the State Enterprise Medical Procurement of Ukraine, which will allow the speedy purchasing of medical goods for the Ministry of Healthcare of Ukraine.

Workplace equity Allegation Against

SAP is accused of discriminating against employees by age in hiring

SAP is accused of discriminating against employees based on age by refusing to hire them into open positions.

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theregister.com
His lawyers claim SAP also discriminated against him based on his age in refusing to hire him into numerous open positions.
Former SAP exec accuses company of age discrimination

Corporate conduct Confirmed Against

A U.S. District Judge ruled that most claims in an antitrust case against SAP may proceed

Chhabria Rules Most Claims in Antitrust Case Against Software Giant SAP May Proceed.

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law.com
Chhabria Rules Most Claims in Antitrust Case Against Software Giant SAP May Proceed

Corporate conduct Confirmed Against

EU opens investigation into SAP's ERP support practices

The European Commission opened a formal investigation to assess whether SAP distorted competition in the aftermarket for maintenance and support services related to its on-premises ERP software.

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ec.europa.eu
Commission opens investigation into possible anticompetitive practices by SAP regarding maintenance and support services for its popular business management software Brussels, 25 September 2025 The European Commission has opened a formal investigation to assess whether SAP may have distorted competition in the aftermarket for maintenance and support services related to an on- premises type of software, licensed by SAP, used for the management of companies' business operations and called Enterprise Resource Planning (‘ERP'), in the European Economic Area (‘EEA').
ec.europa.eu
SAP also provides maintenance and support services for its ERP software, which include regular updates and technical assistance for its business customers to keep the software operational.
ec.europa.eu
An overview of all activities is available online. The European Researchers' Night and Researchers at Schools are initiatives funded by the Marie Skłodowska-Curie Actions (MSCA), part of the EU's programme for research and innovation Horizon Europe . (For more information: Eva Hrnčířová – Tel.: +32 2 298 84 33; Eirini Zarkadoula – Tel.: +32 460 76 57 13) Commission opens investigation into possible anticompetitive practices by SAP regarding maintenance and support services for its popular business management software The European Commission has opened a formal investigation to assess whether SAP may have distorted competition in the aftermarket for maintenance and support services related to an on- premises type of software, licensed by SAP, used for the management of companies' business operations and called Enterprise Resource Planning (‘ERP'), in the European Economic Area (‘EEA').
ec.europa.eu
Commission opens investigation into possible anticompetitive practices by SAP regarding maintenance and support services for its popular business management software Brussels, 25 September 2025 The European Commission has opened a formal investigation to assess whether SAP may have distorted competition in the aftermarket for maintenance and support services related to an on- premises type of software, licensed by SAP, used for the management of companies' business operations and called Enterprise Resource Planning (‘ERP'), in the European Economic Area (‘EEA').
ec.europa.eu
Commission opens investigation into possible anticompetitive practices by SAP regarding maintenance and support services for its popular business management software Brussels, 25 September 2025 The European Commission has opened a formal investigation to assess whether SAP may have distorted competition in the aftermarket for maintenance and support services related to an on- premises type of software, licensed by SAP, used for the management of companies' business operations and called Enterprise Resource Planning (‘ERP'), in the European Economic Area (‘EEA').
cnbc.com
According to the Commission, the investigation will assess "whether SAP may have distorted competition in the aftermarket for maintenance and support services related to an on-premises type of software, licensed by SAP, used for the management of companies' business operations."