Responding department: Sustainability
Stock Exchange Symbol: (SAP:GR)
Does your company have a publicly available commitment to respect human rights?
[link] (SAP Code of Business Conduct, Global Health and Safety Management Policy, Supplier Code of Conduct, Partner Code of Conduct) [link] (Our integrated company report with more information about human rights at SAP. Quotes of the company report were used to respond to the questions below.)
More information under Guideline 16 of the UN Guiding Principles on Business and Human Rights: "Political Engagement”.
How are human rights governed in your company?
We consider ourselves to be bound to respect human rights for ethical as well as economic reasons. The adherence to high ethical standards helps us to protect our reputation, to promote diversity in our company and to hire highly qualified people and make them stay with us. In this manner, we can create fair and ethical working conditions for our employees and increase our potential for innovation.
In 2011, we clarified in our Commitment to Respect Human Rights that we respect and support the principles elaborated in the Universal Declaration of Human Rights and in the Convention of the International Labour Organisation (ILO). This commitment, which was approved by our management, includes all our operations and subsidiaries of SAP worldwide.
- Where is the lead responsibility for human rights located, and why?
The subject of human rights lies within the sustainability team, which belongs to the board aeea Global Finance & Administration. In close cooperation with human resources, issues such as our Human Rights Commitment Statement are adressed. In addition, our board has approved the Human Rights Commitment Statement.
- Does any board member or board committee have oversight of human rights issues?
Our efforts on human rights are made transparent to all employees. Our Human Rights Commitment Statement is also available externally. On top of that, the results of our annual audits to check compliance are communicated to our top management (e.g. in quarterly risk reports).
- What is the relevance of human rights considerations to the company’s business model and strategy?
Although we regard human rights as an important topic in our company, our materiality analysis has shown that human rights are not one of our key issues. More information can be found in our Integrated Report
How are human rights managed within your company?
Our Commitment to Respect Human Rights describes the standards we aspire to adhere to in the three core areas of employees, partners and suppliers and solutions. Our sustainability organisation is responsible for the implementation of our Commitment to Respect Human Rights in our day-to-day business. The team collaborates with the HR Department, the Procurement Department and the Product Development Department to develop a detailed plan to ensure the implementation of our standards. To determine whether our measures with regards to the respect of human rights are sufficient, we also consider external comparisons, performance evaluations, audit results and the feedback of our stakeholders. In 2012, we introduced a universal program to verify the adherence to our standards across the business.
We value the respect of human rights not only in relation to our employees, but also in our supply chain and in our solutions. The SAP Code of Conduct for suppliers and the SAP Code of Conduct for partners stipulate that our suppliers and partners also need to respect human rights, adhere to working conditions standards and to provide for a safe and healthy working environment.
What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?
Our Commitment to Respect Human Rights is the result of a consultation about the consequences of our economic activity with regards to human rights. The human rights aspects that are of particular relevance to SAP were identified in collaboration with our stakeholders. We concluded that for us, as a software provider, the aspects of child labour, freedom of assembly and forced labour are of minor relevance. We do not create any material products that would have to be produced by partners or in the premises of suppliers. Moreover, we hire highly qualified and specialised employees, who expect a performance-linked salary and appropriate benefits from us. Nevertheless, through our Commitment to Respect Human Rights and the SAP Code of Conduct, we demand that suppliers respect human rights and working conditions standards in our supply chain. We are also convinced that our employees have good basic conditions to freely express their opinion – which is why the aspect of freedom of assembly is of lesser relevance to us. In our last employee survey, 77% of employees agreed that the working conditions at SAP are marked by mutual trust and respect. At the same time, however, we have also identified complex, ever-changing risks and opportunities in the area of human rights, that are relevant for the whole software industry and that range from freedom of barriers and security to data protection.
For SAP, stakeholder engagement and collaboration are deeply embedded into our process of innovation and the development of our solutions. Before we can design a new solution, we must first understand the issue we are addressing. For this reason, design thinking and co-innovation are essential. To fully understand these responsibilities, we regularly engage with seven key stakeholder groups that are most relevant to our business, as well as our Sustainability Advisory Panel.
For a detailed description of stakeholder engagement, see our Integrated Report
Priority human rights issues: What are some of the priority human rights issues for your company?
- Workplace diversity / non-discrimination
- Forced labour & trafficking
- Sexual harrassment
- Freedom of association
- Access to water
- Freedom of expression & privacy
- Relations with security providers
- Children & child labour
- Racial & ethnic minorities
- Migrants workers
- Others: Data security, Training for Employees
Health: see our Global Health & Safety Management Policy
Workplace diversity, Women, Health: see our Integrated Report, Chapter Employees and Social Investments
Workplace diversity, sexual harassment, freedom of expression, freedom of association, product misuse, women, children: see our Global Human Rights Commitment Statement
Transparency of payments to governments: see our Integrated Report, chapter Public Policy
How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?
We communicate our engagement externally via our website SAP.com, as well as through our Integrated Report. As a signatory of the United Nations Global Compact, we have been communicating our progress on human rights engagement externally since 2000. Furthermore, our Human Rights Commitment Statement is available internally in our employee portal. In particular, new employees have access to an onboarding portal, which refers to all of our policies.
What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?
In addition to this, further avenues are available for employees to report problems related to their working environment. For example, they can turn to colleagues who have been trained as internal mediators. Our Global Compliance Office is responsible for the respect of our anti-corruption guidelines and antitrust law, as well as for other issues related to our business behaviour. To guarantee the respect of high standards, we offer training to our employees alongside the complaint mechanisms. This includes the entire spectrum of human rights aspects that are particularly relevant for our company: security, data protection and anti-discrimination.
An independent and neutral authority, the ombudsperson is the main contact person for our global employee base to address issues and settle disputes. This work includes the investigation of employee complaints and the mediation of fair settlements. All employees can reach out to the ombudsperson on a confidential basis. The ombudsperson also helps the Executive Board analyze HR-related complaints and consider ways to address potential issues before they occur.
Employees have access to other channels to raise concerns about the workplace, including colleagues who are trained to be part of our internal mediation pool. Our LCIO oversees our antibribery and antitrust policies, along with other issues related to our business conduct. In addition to such grievance procedures, we work to uphold high standards by providing training to our employees on human rights issues that are most relevant to our business – namely, security, privacy, and antidiscrimination.
Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?
Information about membership of SAP in relation to sustainability and human rights can be found in our integrated report: [link]. Moreover, we cover social investments of SAP in our integrated report: [link]
Examples of these include multi-stakeholder initiatives such as the Fair Labor Association, Global Network Initiative, Voluntary Principles on Security & Human Rights; industry initiatives such as the Electronic Industry Citizenship Coalition; UN Global Compact; other international, regional or local initiatives.
SAP has been an UN Global Compact signatory since 2000.
Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.
In 2011, we explained in our Commitment to Respect Human Rights ([link]) that we respect and support the fundamental principles and rights at work elaborated in the Universal Declaration of Human Rights and in the Convention of the International Labour Organisation (ILO).
In the implementation of this commitment we use the UN framework for business and human rights („Protect, Respect and Remedy“).
In 2012, we launched a global internal audit program to verify that our subsidiaries adhere to our standards. Since then, we conduct regular audits to check internal compliance with this policy. In 2015, we conducted a labor audit in our locations SAP China Labs and AGS operations in Shanghai and Beijing. There were no material findings within the audit. However, areas for improvement were identified and include establishing an employee council, enhancing air quality inside the buildings, and increasing awareness of team-building events.
We welcome and support the Guiding Principles on Business and Human Rights to Implement the United Nations “Protect, Respect and Remedy” Framework and seek to continuously embed them in our policies and processes.
What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?
Due to the global orientation of the company, we see particular challenges in relation to the various country-specific legislations, for example with regards to freedom of assembly and non-discrimination.
In terms of our suppliers we have to realise that complete transparency in relation to sub-contractors and their human rights commitments is becoming increasingly difficult to achieve, and that this area therefore needs particular attention.