SAP

The role of the administrative, management and supervisory bodies

SAP Executive Board

Christian Klein - Chief Executive Officer (CEO)

• Joined SAP: 1999
• Appointed to the Executive Board: 2018
• Current Executive Board term expires: 2028
• Nationality: German
• Year of Birth: 1980
• Other board memberships: Supervisory Board, adidas AG, Herzogenaurach, Germany (publicly listed)

Dominik Asam - Chief Financial Officer

• Joined SAP: 2023
• Appointed to the Executive Board: 2023
• Current Executive Board term expires: 2026
• Nationality: German
• Year of Birth: 1969
• Other board memberships: Supervisory Board, Bertelsmann Management SE and Bertelsmann SE & Co. KGaA, Gütersloh, Germany (not publicly listed)

Muhammad Alam - SAP Product Engineering

• Joined SAP: 2022
• Appointed to the Executive Board: 2024
• Current Executive Board term expires: 2027
• Nationality: U.S. Citizen
• Year of Birth: 1977

Thomas Saueressig - Customer Services & Delivery

• Joined SAP: 2004
• Appointed to the Executive Board: 2019
• Current Executive Board term expires: 2028
• Nationality: German
• Year of Birth: 1985
• Other board memberships: Board of Directors, Nokia Corporation, Espoo, Finland (publicly listed)

Sebastian Steinhaeuser - Chief Operating Officer

• Joined SAP: 2020
• Appointed to the Executive Board: 2025
• Current Executive Board term expires: 2028
• Nationality: German
• Year of Birth: 1985

Gina Vargiu-Breuer - Chief People Officer, Labor Relations Director

• Joined SAP: 2024
• Appointed to the Executive Board: 2024
• Current Executive Board term expires: 2027
• Nationality: German
• Year of Birth: 1975

Supervisory Board

The Supervisory Board of SAP SE discharged the duties imposed on it by the law and by the Company's Articles of Incorporation. It advised the Executive Board on an ongoing basis with regard to the running of the Company, and it scrutinized and monitored the work of management.

The Supervisory Board received regular, full, and timely reports from the Executive Board, both from members in person and in written documents. The Supervisory Board and its various committees were also in regular exchange with senior internal officers.

Dr. h.c. mult. Pekka Ala-Pietilä - Chairperson (since 5/15/2024) Lars Lamadé - Deputy Chairperson Dr. Friederike Rotsch - Lead Independent Director

The Supervisory Board held four regular meetings and seven extraordinary meetings in 2024. The following committees were active:

• Personnel and Governance Committee
• Audit and Compliance Committee
• Finance and Investment Committee
• Product and Technology Committee (since May 15, 2024)
• Nomination Committee
• Government Security Committee (since January 1, 2024)

The Supervisory Board addressed key topics including:

Strategy and Transformation

The Executive and Supervisory Boards discussed SAP's corporate strategy and cloud transformation on numerous occasions in 2024. The Supervisory Board was updated on the restructuring program and discussed its implementation with the Executive Board.

Sustainability

At SAP, sustainability has two main dimensions: providing solutions that help customers do business in a sustainable way, and aligning our business activities with sustainability targets to lead by example. Throughout the year, sustainability topics were discussed at meetings of the full Supervisory Board and various committees. The Audit and Compliance Committee looked closely at the new European Corporate Sustainability Reporting Directive (CSRD) and at how SAP technologies for sustainability reporting can be used to track ESG data.

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

The Supervisory Board received regular, full, and timely reports from the Executive Board, both from members in person and in written documents. The Supervisory Board and its various committees were also in regular exchange with senior internal officers. This ensured that they were always up to date, also between meetings, on the Company's strategy, planning, business performance, risks, risk management, compliance, and on transactions of special significance for SAP.

In its reports, the Executive Board advised the Supervisory Board about any deviations in business performance from the budgets or targets set, and explained the reasons for them. The Supervisory Board questioned and probed the Executive Board on its reports to satisfy themselves that they were plausible.

The Supervisory Board chairperson and the CEO were in regular contact, such that the Supervisory Board chairperson was always informed without delay about all material events. Moreover, the chairperson of the Supervisory Board and the CEO regularly discussed SAP's strategy, business performance, risk position, risk management, and compliance.

Sustainability Matters

Throughout the year, sustainability topics were discussed at the meetings of the full Supervisory Board and at those of the various committees. The Audit and Compliance Committee looked closely at the new European Corporate Sustainability Reporting Directive (CSRD), which obliges companies to meet new, more detailed, sustainability reporting standards.

The Committee and the Supervisory Board were informed about the process used to identify, assess, and manage the impacts, risks, and opportunities (IROs) related to sustainability. At the meeting on April 11, 2024, the Chief Sustainability Officer advised about new statutory reporting requirements, the stipulations of the German Supply Chain Due Diligence Act, the action SAP is taking to ensure responsible AI practices, and its plans to reduce its emissions.

The Supervisory Board was given the opportunity to build on its sustainability expertise by attending a training course the Company held in October 2024 on sustainability at SAP. SAP's sustainability solutions are crucial to its business, and because the topic of sustainability is relevant in many key aspects of SAP's operations, these aspects are also central to SAP's strategy.

Integration of sustainability-related performance in incentive schemes

As part of the Executive Board compensation system, the Supervisory Board set performance targets for the short-term incentive (STI) 2024 and grant amount for the 2024 tranche of the long-term incentive (LTI) 2024. The Personnel and Governance Committee extensively prepared the Supervisory Board's deliberations and resolutions on Executive Board compensation.

At the November 2024 meeting, the Supervisory Board adopted the adjustment to the targets and achievement levels in the Executive Board's STI and LTI plans. The Committee also prepared the resolution on replacing the operating margin increase with free cash flow as one of financial key performance indicators (KPIs) in the STI 2025, as investors are now placing much greater importance on free cash flow than on the increase in operating margin.

From the 2025 tranche of the LTI 2024, total revenue will replace software license, support, and service revenue, and cloud revenue, as the revenue KPI. The Supervisory Board has given greater weight to cloud revenue to reflect its relevance to the Company's cloud transformation.

The Supervisory Board ascertained that, in terms of amount, structure, and objective criteria, the Executive Board members' compensation for 2024 was reasonable and appropriate, and proportionate to the Company's financial situation, profit, and outlook. An independent opinion obtained from an outside compensation consultant informed this decision.

Statement on due diligence

SAP conducts due diligence processes as part of its governance and risk management framework. The Executive Board advised the Supervisory Board about the terms of the settlement agreement that SAP reached with the U.S. Department of Justice regarding ongoing compliance matters. The Supervisory Board and Executive Board agreed that the Company must have a zero-tolerance policy on compliance breaches.

The Supervisory Board discussed with the Executive Board the stipulations of the German Supply Chain Due Diligence Act and the action SAP is taking to ensure responsible AI practices. SAP's Chief Sustainability Officer reported on new statutory reporting requirements and due diligence processes.

The Audit and Compliance Committee regularly discussed ongoing compliance matters, the status of SAP's internal investigations, and its cooperation with authorities on respective cases. The Committee also dealt with the monitoring of SAP's risk management system, internal control system, sustainability reporting, and compliance system.

SAP has established processes to identify, assess, and manage impacts, risks, and opportunities (IROs) related to sustainability as part of its due diligence framework. This process was reported to and discussed by the Supervisory Board and relevant committees throughout 2024.

Risk management and internal controls over sustainability reporting

The Audit and Compliance Committee comprehensively monitored SAP's risk management system, internal control system, sustainability reporting, and compliance system. The Committee regularly discussed these systems as recurring agenda items.

The Committee confirmed that, as part of its supervisory work, it had addressed the SAP Group's internal control, risk management, and internal auditing systems, and found the systems to be effective.

The auditor reported that it had not identified any material weaknesses in SAP's internal control and risk-management systems for financial reporting. Both the Audit and Compliance Committee and the Supervisory Board asked detailed questions about the form, scope, and results of the audit.

SAP has established processes to identify, assess, and manage the impacts, risks, and opportunities (IROs) related to sustainability. The Committee and the Supervisory Board were informed about this process throughout 2024.

The Audit and Compliance Committee looked closely at the new European Corporate Sustainability Reporting Directive (CSRD) and at how SAP technologies for sustainability reporting, such as the SAP Sustainability Control Tower solution, can be used to track ESG data so that companies can meet sustainability targets.

BDO AG Wirtschaftsprüfungsgesellschaft provided limited assurance on the group sustainability statement included in the combined management report, and reasonable assurance on selected sustainability information in accordance with International Standard on Assurance Engagements (ISAE) 3000 (Revised).

Strategy, business model and value chain

Our Purpose

At SAP, we remain steadfast in our purpose to "help the world run better and improve people's lives." Together with our customers, we not only rise to meet today's challenges, but we are also shaping the future by empowering each other to continuously improve and deliver better outcomes.

Our Vision

Our vision of bringing out the best in every business reflects our commitment to transform organizations globally. We aim to build a future where businesses adapt rapidly to changes and opportunities, embed sustainability in their operations, and drive efficiency throughout the value chain. Our commitment to this vision is based on three pillars:

Agile Business Transformation at Scale

To stay competitive in a rapidly changing landscape, businesses need to transform at scale with agility. Our cloud solutions and real-time data insights, supported by our platform, enable organizations to achieve greater flexibility and efficiency and to adapt rapidly to evolving demands.

Achieve More Across the Value Chain

We assist organizations in utilizing collective intelligence to help achieve efficiency, resilience, and agility across the whole value chain. By embedding AI and connecting end-to-end business processes – from finance to supply chains, and human resources to customer relations – we fuel efficient growth throughout businesses.

Sustainability at Your Core

We have evolved beyond mere sustainability aspirations to actionable, sustainable outcomes. Our SAP Green Ledger solution aims to ensure robust, auditable sustainability practices are a natural extension of business operations.

Our Business Model

We create value by first identifying the business needs of our customers and then developing and delivering a portfolio of cloud solutions, services, and support that address these needs. We strive to continuously improve our solutions, identify further business needs, and deliver enhanced value to our customers.

We derive revenue from fees charged to our customers for subscriptions to use our cloud solutions. Software licenses, on-premise support, consulting, development, training, and other services also contribute significant revenue.

Our Product Strategy

The recently launched SAP Business Suite leverages the powerful combination of applications, data, and AI. It offers a comprehensive set of integrated solutions, combining our core cloud ERP and line-of-business (LoB) applications to seamlessly connect functions across the business end to end.

We have adopted an AI-First, Suite-First strategy:

AI-First means we are fundamentally rethinking our approach to product development, offering our generative AI copilot, Joule, available in many of our most frequently used process steps.

Suite-First describes our objective of delivering a consistent, or suite-like, experience across our portfolio, aiming to ensure faster time to value for customers.

Geographic Presence and Value Chain

SAP is a global company headquartered in Walldorf, Germany, with a global presence employing more than 109,000 people as at December 31, 2024. The SAP Group has operations across multiple regions and serves customers worldwide through our cloud solutions, software licenses, support services, and consulting offerings.

Interests and views of stakeholders

SAP maintains active dialogue with various stakeholder groups to understand their interests and incorporate their views into our strategy and business model development.

Investors and Financial Community

SAP maintained strong engagement with the investment community in 2024. Throughout the year, members of the Executive Board and the Investor Relations team engaged with institutional investors, analysts, and private investors worldwide to discuss the company's strategy, execution, business developments, and how SAP is helping customers meet organizational challenges.

The IR team, together with senior management, conducted more than 500 meetings in 2024 to maintain active dialogue with investors and analysts. These included one-on-one phone calls, video conferences, and roadshows. Members of the Executive Board and IR team attended more than 20 conferences across an expanded geographical mix.

We continued our dialogue with investors, focusing on environmental, social, and governance (ESG) topics, and provided them with insights into our sustainability policies and products.

Customers

We create value by first identifying the business needs of our customers and then developing and delivering a portfolio of cloud solutions, services, and support that address these needs. Our interests and views of stakeholders in relation to strategy and business model are continuously incorporated into our product development and service delivery.

2024 was another year of strong customer wins, including companies from the "who is who" of the tech, energy, retail, automotive, and manufacturing sectors. By the end of 2024, more than 34,000 cloud customers worldwide use SAP Business AI.

Employees

Employee engagement and feedback are integral to our strategy development. Employee surveys are conducted regularly to gather insights on engagement, management feedback, and other aspects of the work experience. The results of employee surveys are discussed in detail at the People and Culture Committee and inform actions and improvements in our people strategy.

Shareholders

SAP representatives engaged with retail shareholders at virtual and in-person events. We provide a wide range of information online about SAP and its stock, and maintain regular communication through various channels including LinkedIn, telephone hotline, and email.

Given the company's success in 2024, the Supervisory Board and Executive Board propose a dividend of €2.35 per share for approval at the Annual General Meeting in May, marking an increase of 6.8% compared to the previous year.

Material impacts, risks and opportunities and their interaction with strategy and business model

List of Material IROs

SAP conducted a comprehensive double materiality assessment (DMA) in accordance with ESRS requirements. The material topics identified are environmental and social matters, and their associated impacts, risks and opportunities.

Material Topics:

• Climate Change (including Climate change mitigation and Energy)
• Circular Economy (E-Waste)
• Own Workforce
• Workers in the Value Chain
• Security, Cloud Compliance, and Data Protection and Privacy
• Responsible AI
• Business Conduct

Topics assessed as not material:

• Pollution
• Water and Marine Resources
• Biodiversity and Ecosystems
• Affected Communities
• Geopolitical Uncertainty
• Climate Change Adaptation

Detailed IRO Table

The following table presents all material IROs, sorted by topic, their relation to SAP's strategy and business model, value chain location, time horizon, and type:

Linkage Between IROs and Strategy / Business Model

SAP's sustainability strategy focuses on three pillars – climate action, circularity, and social responsibility – and on the cross-layer of holistic steering and reporting. These pillars reflect the topics that the double materiality assessment identified as material.

Sustainability is firmly anchored in SAP's corporate strategy, governance, and Executive Board compensation system. The environmental, social, and governance topics are embedded in our corporate strategy.

Climate and Circular Economy: IROs that relate to data centers (e-waste and carbon emissions) are connected to SAP's strategy and business model. SAP's core position in the value chain is to innovate, develop, deliver solutions, and support customers. The cloud transformation is a key strategic initiative that significantly impacts GHG emissions.

Own Workforce and Social: IROs related to equal opportunities and equal treatment, training and development are considered connected to SAP's strategy and business model. The People Agenda, established in 2024, is a holistic system and one of the pillars in SAP's corporate strategy.

Technology and Security: IROs related to AI, security, cloud compliance, and data protection and privacy are connected to SAP's strategy and business model as these are fundamental to SAP's product offerings.

Business Conduct: IROs related to business conduct are connected to SAP's strategy and business model.

Value Chain Location

SAP's value chain comprises:

• Upstream value chain: Suppliers that provide products/services (e.g., hyperscale services, IT hardware)
• Own operations: Internal activities, resources, and supporting activities (e.g., HR, facilities)
• Direct business: Core business activities (development, marketing)
• Downstream value chain: Customers (B2B) and partners

The main business actors in the upstream value chain are suppliers, and in the downstream value chain are customers and the partner ecosystem.

Time Horizons

SAP applies the time horizons as defined in ESRS 1:

• Short term: up to one year
• Medium term: more than one and up to five years
• Long term: more than five years

How Material IROs Interact with the Business

Impact on SAP's Financial Position:

SAP is not aware of any material current financial effects on SAP's financial position, financial performance, or cash flows resulting from risks and opportunities identified in the course of the materiality assessment. However, SAP sees a significant year-over-year increase in sales of sustainability solutions.

SAP has continuously adapted to changes in the business environment, leveraging technological expertise to stay ahead. The commitment to innovation and sustainability has allowed SAP to address environmental and social impacts as an enabler and exemplar while also capitalizing on emerging market trends. The Company's valuation on capital markets clearly shows the trust people have in the future development of SAP.

Physical Risks: SAP conducted a climate scenario analysis for a global temperature increase of 1.5°C and above (SSP5-RCP8.5). No business-critical physical risks were identified. SAP does not foresee that climate change hazards will affect owned or colocation data centers in the foreseeable future (beyond five years).

Transition Risk: SAP is not significantly exposed to transition risks, since it does not operate in high climate risk sectors. SAP does not invest in or maintain significant carbon-intensive infrastructure that would lead to locked-in GHG emissions that could jeopardize the net-zero target.

Resilience to Identified IROs

Climate Change: In light of the risks and opportunities described, SAP considers its business model and strategy to be resilient in the context of a changing climate.

SAP's net-zero commitment aims to reduce Gross Greenhouse Gas Emissions (market-based) by at least 90% across the relevant value chain by 2030. The target has been validated and approved by the Science Based Targets initiative (SBTi), compatible with limiting global warming to 1.5°C.

SAP acknowledges recent reports from various companies, including some vendors, stating they are reconsidering or adjusting their net-zero targets. Given the increasing demand for energy due to the widening use of artificial intelligence, SAP is closely monitoring progress and evaluating whether it can achieve the net-zero target by 2030 as planned or if adjustments may be necessary.

SAP's decarbonization and transformation plan tackles four main areas:

1. Cloud transformation: Moving on-premise solutions to the cloud represents the most important GHG-reduction lever
2. Upstream supply chain: Working on reducing supply chain emissions through supplier partnerships and refining procurement processes
3. Own operations: Driving real avoidance and reduction of GHG emissions
4. Carbon removals: Investing in nature-based and technical removals to neutralize remaining residual GHG emissions by 2030 (maximum: 10%)

Resource Use and Circular Economy: SAP commits to achieving zero e-waste in its own operations by 2030, meaning diverting more than 90% of electrical and electronic waste from incineration and landfill.

Own Workforce: SAP actively prioritizes the interests, views, and rights of its employees in all operations, including the business model and strategy process. The People Agenda, established in 2024, is a holistic system with three key strategic pillars built on a strong foundation.

Business Conduct: SAP is committed to doing business with integrity, meeting the highest standards of ethics and compliance, and employing and safeguarding responsible business practices.

Description of the process to identify and assess material impacts, risks and opportunities

Overview of the Double Materiality Assessment Process

To identify the sustainability topics for disclosure in our Integrated Report, we conducted a comprehensive double materiality assessment (DMA) in accordance with the requirements of new the European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD).

We previously reported under the standards of the Global Reporting Initiative (GRI). From 2024, SAP will follow the ESRS double materiality approach. Under this approach, sustainability topics are evaluated from both financial (risks and opportunities) and impact (positive and negative impacts) perspectives; a single impact, risk, or opportunity (IRO) triggers materiality for an entire topic.

Step-by-step Methodology

To determine our material sustainability topics, we first identified the relevant and SAP-specific IROs for each ESRS sustainability topic (for example, climate change and own workforce). We based our assessment on the materiality results from previous years and considered all ESRS-relevant sustainability topics, sub-topics, and sub-sub-topics.

The assessment was carried out by our internal stakeholders and experts, and by the applicable business units. They and our sustainability team were involved throughout the process, from identifying and assessing the topics, to deriving the possible consequences of the material impacts, risks, and opportunities. This approach allowed us to directly address any influences resulting from the assessment.

We distinguished between potential and actual positive and negative impacts, and risks and opportunities that derive from dependencies on natural, human, and social resources. The screening covers the overall SAP value chain. In this context and in relation to the environmental, social, and governance topics, a positive impact is any action that improves the status quo, and a negative impact is a detrimental effect on it.

Inputs to the Assessment

Internal Experts

The materiality of the IROs we identified was assessed by internal experts from, for example, our Total Rewards and Data Center Management teams. We assigned the IROs related to a specific topic to the respective team or teams for assessment. While we selected these experts carefully, due to the nature of the materiality assessment their judgment determines its outcome. Consequently, the results of our materiality assessment are influenced by our choice of experts.

Value Balancing Alliance Methodology

We use the Value Balancing Alliance (VBA) methodology to measure and value the impact that SAP's business activities have on society and the environment.

For this purpose, we follow the impact measurement and valuation approach. This approach refers to the process of first measuring the physical impact, typically by way of ESG indicators, and then using impact valuation factors to convert these indicators into monetary values. Attributing a monetary value to ESG indicators makes it easier to compare sustainability and financial metrics. It also allows material sustainability topics to be incorporated into financial accounting systems and, as a result, enables meaningful sustainability management in line with financial indicators.

SAP applies widely used, state-of-the-art science-based valuation factors to integrate non-financial, monetary performance indicators that companies, investors, and other stakeholders can use for comparison. Methods continue to mature year over year, and various challenges still need to be addressed.

Internal and External Data Sources

Each IRO was screened and reviewed by an in-house expert and cross-checked by the Sustainability team and the Global Risk & Assurance Services team. As input parameters, SAP used internal and external sources (including, but not limited to, data points from the GHG protocol, and benchmarks from sector-specific financial materiality reports from the Sustainability Accounting Standards Board (SASB), the European Financial Reporting Advisory Group (EFRAG), and the Value Balancing Alliance (VBA)).

Scoring Criteria

Impact Materiality

Impacts are scored based on severity (determined by scale, scope, and irremediable character). For potential impacts, likelihood is also considered.

Financial Materiality

We prioritize risks by using the methods proposed in ESRS and in the German Supply Chain Act. The financial and non-financial impacts, risks, opportunities, and responses relevant for ESRS are prioritized by risk level (severity/impact x probability) and time horizon, with the number 1 signifying the highest priority. We prioritize all other risks not related to sustainability at SAP using the same approach.

Threshold for Materiality

SAP discloses only the datapoints related to material IROs. In some cases, a specific section has been created to fulfill the disclosure requirements for a single subtopic or sub-subtopic. To determine whether a datapoint was material for us, we used the flow chart from ESRS 1 Appendix E.

The results of our materiality assessment show that the material topics for SAP are environmental and social matters, and their associated impacts, risks and opportunities.

Value Chain Mapping

The screening covers the overall SAP value chain. Unless otherwise stated, SAP's entire up- and downstream value chain described above is covered in the Group Sustainability Statement. Whenever we have used the option to omit certain information because it was classified as sensitive or it is information about intellectual property, know-how, or results of innovation, we have stated that fact in the respective section. Datapoints that were classified as not material have not been included in the report.

Frequency and Last Review

The materiality assessment was conducted in 2024. Our 2022 and 2024 materiality assessments differ as follows:

• Our 2024 materiality assessment refers to ESRS topics and sub-topics, whereas our 2022 assessment referred to issues. Issues were not defined by a standard and can, in some cases, be comparable to a topic (for example, biodiversity was designated as an issue in our 2022 assessment and is a topic in the 2024 assessment), a sub-topic, or a sub-sub-topic (the well-being, health, and safety issue, in our 2022 assessment is comparable to the work-life balance and health and safety sub-sub-topics in our 2024 assessment).

• In 2024, we conducted an impact materiality assessment, whereas, in 2022, we completed an inside-out assessment under the GRI standards. The method used in each case is comparable but details, such as the scale used, differ.

• Our 2024 financial materiality assessment followed a different approach to the one we used for the outside-in assessment in 2022. In 2024, we considered each topic's magnitude and likelihood, rather than its financial, strategic, and regulatory relevance to SAP's business success and resilience.

Approval and Governance

SAP's CEO and CFO approved the materiality assessment. After this initial approval, the ESG Steering Board is then involved in the continuous assessment of the measures and targets related to the IROs. For more information, see the Sustainability Governance section.

Stakeholder Engagement

In our materiality assessment, we also considered the input of several SAP sustainability experts from various units and regions, taking different stakeholders' perspectives into account.

At SAP, stakeholder engagement and collaboration are deeply embedded in our process of innovation and the development of our products and services. Before we can design a new solution, we must first understand the issues we are addressing. This is why we regularly liaise with stakeholder groups, including our sustainability and AI ethics advisory panels.

Key stakeholder groups engaged include:

• Customers: Through customer engagement programs
• Employees: Through various employee engagement processes (see Own Workforce section)
• Financial Analysts and Investors: Through regular engagement with the investment community
• Partners: Through the SAP Partner Portal and regular communications
• Non-Profit Organizations and Academia: Through ongoing dialogue and the SAP University Alliances program
• Sustainability Advisory Panel: Provides strategic guidance, consisting of renowned sustainability experts from NGOs, customers, and partners. The panel held four virtual meetings in 2024 discussing topics including the double materiality assessment, corporate sustainability strategy, and solution development strategy.
• AI Ethics Advisory Panel: Comprises academics, policy experts, and industry experts providing feedback on ethical AI

Transition plan for climate change mitigation

Scope of the plan

SAP's transition plan covers Scope 1, Scope 2 (market-based), and all business-relevant Scope 3 value chain emissions in line with the GHG Protocol baseline.

SAP is active only in the software and IT services sector, as defined by the ESRS SEC1 sector classification standard.

The plan covers SAP's entire value chain:

• Own operations (Scope 1 and 2)
• Upstream supply chain (Scope 3 upstream)
• Downstream value chain including product-in-use emissions (Scope 3 downstream)

Target year(s) for net zero / carbon neutral

Net-zero target year: 2030

SAP aims to reach net zero across its value chain in line with a 1.5°C future by 2030.

Scope 1, 2, 3 reduction milestones with baseline years

2024 Performance:

• Total Gross GHG Emissions (market-based): 6.9 million tons CO2e (stable vs. 2023: 6.9 million tons)
• GHG Emissions Scope 3 Upstream: 1.3 million tons CO2e (19% of total)
• GHG Emissions Scope 1 & 2 (market-based): 0.1 million tons CO2e (2% of total)
• GHG Emissions Scope 3 Downstream: 5.5 million tons CO2e (80% of total)

Alignment with 1.5°C / SBTi validation status

The net-zero target has been validated and approved by the Science Based Targets initiative (SBTi), which verified that SAP's target is compatible with limiting global warming to 1.5°C as advocated by the Paris Agreement.

SAP's ambitious climate change mitigation commitment has been recognized by the investment market, as demonstrated by SAP's inclusion in the EU Paris-aligned benchmarks.

Key levers / decarbonization pillars

SAP's decarbonization and transformation plan tackles four main areas:

1. Cloud transformation

Moving on-premise solutions to the cloud represents SAP's most important GHG-reduction lever. SAP's own data centers and colocations are powered with 100% renewable energy. SAP aims to increase the share of renewable energy in upstream and downstream value chain by working with suppliers (specifically hyperscale providers) and customers.

Actions:

2. Upstream supply chain

SAP is working on reducing supply chain emissions by maintaining strong supplier partnerships and adjusting internal procurement processes and policies.

Actions:

SAP recognizes interdependencies with suppliers and their decarbonization strategies and timelines, which are beyond SAP's direct control. Growing demand for energy due to increasing use of artificial intelligence could negatively impact GHG emissions in upstream supply chain.

3. Own operations

SAP aims to drive real avoidance and reduction of GHG emissions by:

• Transitioning car fleet to electric vehicles
• Strengthening environmental and energy management system (ISO 14001 and ISO 50001)

4. Carbon removals

By investing in nature-based and technical removals, SAP aims to neutralize remaining residual GHG emissions by 2030 (maximum: 10% in line with Science Based Target Initiative standard for net-zero targets).

In the future (in 2030), SAP plans to retire a maximum of 690,000 carbon removal credits and equivalent tons of CO2e in line with SBTi criteria. A share will be generated by existing contractual agreements and long-term commitments such as SAP's investment in the Livelihoods Carbon Funds (LCF).

CapEx / investment commitments

No specific CapEx or investment commitments are disclosed in the excerpts provided.

Locked-in emissions and stranded asset analysis

SAP does not invest in or maintain significant carbon-intensive infrastructure that would lead to locked-in GHG emissions that could jeopardize the net-zero target. On the contrary, SAP is investing in countering measures such as:

• Transitioning car fleet from combustion-type vehicles to electric vehicles
• Operating data centers and office buildings with renewable energy sources

Use of carbon credits / removals

Maximum carbon removals: 10% of total emissions by 2030 (maximum 690,000 tons CO2e) in line with SBTi Corporate Net-Zero Standard.

Beyond the value chain - Climate finance contributions:

Until 2030, SAP is committed to annually financing climate projects that reduce and remove more CO2 from the atmosphere than SAP's own operations (including Scope 1 and 2, and business travel GHG emissions) produce in a year.

2024 Climate Finance Performance:

• Total: approximately 276 kilotons CO2e
• Direct funding: 47 kilotons CO2e
• Carbon credits: 229 kilotons CO2e

Projects include reforestation, forest protection, improved forest management, rural energy, and agroforestry. Carbon credits received from long-term investment in Livelihoods Carbon Funds (LCF) and carbon retailers.

These contributions are voluntary and do not reduce SAP's carbon footprint until the company reaches its reduction and net-zero target.

Contractual instruments (Scope 2):

In 2024, SAP purchased Energy Attribute Certificates (EACs) totaling 308,000 MWh.

• 99% of Scope 2 location-based emissions covered by contractual instruments
• GHG Emissions Scope 2 (location-based): 120 kilotons CO2e
• GHG Emissions Scope 2 (market-based): 1 kiloton CO2e
• Reduction from contractual instruments: 118 kilotons CO2e

Types of contractual instruments:

• 100% unbundled instruments (EACs)
• 0% bundled instruments (insignificant portion of green tariffs in selected locations)

SAP purchases EKOenergy-certified electricity and contributes to EKOenergy's Climate Fund.

Governance and progress measurement

SAP tracks GHG emission reduction targets using an established protocol involving regular assessment. Progress is reviewed in quarterly steering committee meetings sponsored by SAP's CEO and CFO.

After each quarterly assessment, results and deviations are documented. Insights are used to adjust targets as needed.

Executive Board incentives: 10% of Executive Board members' variable long-term incentive (LTI) compensation for 2024 is determined by the Company's progress on its carbon impact target. The Supervisory Board assesses and approves targets annually for the next LTI tranche.

Climate risks and opportunities assessment

In Q1 2024, SAP conducted a climate scenario analysis for global temperature increase of 1.5°C and above (SSP5-RCP8.5), focused on data center and colocation locations.

Physical risks: No business-critical physical risks identified. SAP's business success does not depend exclusively on office facility availability.

Transitional risks: Regular risk management process and materiality assessment did not identify significant short-, medium-, or long-term transitional risks related to climate change, or major impact on SAP's assets.

Opportunities identified: Increasing demand for software solutions that track GHG emissions.

Resilience: SAP considers its business model and strategy resilient in the context of a changing climate.

In 2025, SAP plans to conduct a more detailed climate risk and resilience analysis covering all sites and value chain implications.

Monitoring and evaluation statement

SAP acknowledges recent reports from various companies, including some vendors, stating they are reconsidering or adjusting net-zero targets. Given these developments and increasing energy demand due to widening use of artificial intelligence, SAP is:

"closely monitoring progress on our net-zero plans and continuously evaluate whether they need adjustments, considering the rise in demand for energy due to the use of artificial intelligence and the fact that some of our vendors may not achieve their expected emission reductions, which contribute to our net-zero goal."

SAP states: "we are closely monitoring our progress and evaluating whether we can achieve our net-zero target by 2030 as planned or if we might need to adjust it."

Integration with business model and financial planning

The transition plan is closely connected to SAP's business model and financial planning according to corporate business trajectory and financial forecasts. This ensures incorporation of:

• Estimated company growth
• Cloud development projections
• Comprehensive emissions plan reflecting anticipated developments
• Investments in reducing GHG emissions

This approach ensures climate change mitigation actions are viewed as an integrated element of:

• Financial growth strategy
• Corporate risk management
• Technology adoption
• Product portfolio development

Leveraging SAP's own solutions

In all four decarbonization areas, leveraging SAP's own solution portfolio is fundamental to improve management and planning of initiatives, resources, and value chain partner relationships to achieve net zero by 2030.

Policies related to climate change mitigation and adaptation

SAP does not disclose a specific named climate policy for climate change mitigation and adaptation in the provided excerpts.

The company states that it is "currently reworking our Global Environmental Policy, and will publish the updated version in 2025." This indicates that while an environmental policy framework exists, it is under revision and not yet publicly available in its updated form.

Policy Framework Elements

While no specific climate policy is named, SAP describes several elements of its approach to climate change:

Scope:

• The company's climate change mitigation efforts cover its own operations and value chain, including Scope 1, 2 (market-based), and all business-relevant Scope 3 value chain emissions
• The approach addresses "that part of our value chain over which we have a sufficient control"

Governance:

• The net-zero transition plan is reviewed at senior management level
• Progress is reviewed in quarterly steering committee meetings sponsored by SAP's CEO and CFO
• The Supervisory Board assesses and approves targets annually for the Executive Board's long-term incentive (LTI)
• 10% of Executive Board members' variable LTI compensation is determined by progress on the carbon impact target

Alignment with International Standards:

• SAP's net-zero commitment has been validated and approved by the Science Based Targets initiative (SBTi)
• The target is compatible with limiting global warming to 1.5°C as advocated by the Paris Agreement
• SAP is included in EU Paris-aligned benchmarks
• The company follows Task Force on Climate Related Financial Disclosures (TCFD) recommendations
• Climate scenario analysis follows the Does Not Significantly Harm criteria for the EU Taxonomy

Monitoring:

• SAP tracks GHG emission reduction targets using an established protocol with regular quarterly assessments
• After each quarterly assessment, results and deviations are documented
• Insights are used to perform necessary adjustments to targets
• The company plans to conduct a more detailed climate risk and resilience analysis in 2025

Actions and resources in relation to climate change policies

Overview

SAP's sustainability strategy focuses on three pillars – climate action, circularity, and social responsibility – supported by holistic steering and reporting. The company operates through a dual approach as both an enabler (providing sustainability solutions to customers) and an exemplar (reducing emissions in own operations).

SAP has a dedicated business unit reporting directly to the CEO that focuses specifically on driving sustainability impact at SAP and beyond.

Policies

Global Environmental Policy addresses climate change mitigation, energy performance, circularity, and deployment of renewable energy sources. The policy:

• Aligns with UN SDGs, Science Based Targets initiative (SBTi), GHG Protocol and ISO14001
• Applies to SAP SE and its subsidiaries, including all global operations
• Is publicly available and regularly reviewed by internal lines of business and SAP's leadership (CEO has ultimate responsibility)
• Is currently being reworked with updated version to be published in 2025
• Emphasizes cooperation with suppliers, customers, and other stakeholders

Targets Related to Climate Change Mitigation

Net-zero commitment (1.5°C-aligned science-based target - SBTi validated)

• Base year: 2023 (6.9 million tons Gross GHG Emissions market-based)
• Target year: 2030
• Target: Reduce Gross GHG Emissions (market-based) by at least 90% across value chain (Scope 1, 2 and 3) to reach net zero by 2030
• Scope: GHG Protocol-aligned baseline, including Scope 1, Scope 2 market-based, and all business-relevant Scope 3 value chain
• Residual emissions: Maximum 10% carbon removals to neutralize remaining emissions
• Validation: Approved by Science Based Targets initiative (SBTi), compatible with limiting global warming to 1.5°C as advocated by Paris Agreement
• Recognition: SAP included in EU Paris-aligned benchmarks

Actions as Enabler (Customer Solutions)

SAP provides cloud-based, AI-enabled sustainability solutions to customers across 25 industries:

Sustainability software portfolio (scope: downstream value chain):

• SAP Sustainability Control Tower
• SAP Sustainability Footprint Management
• SAP Sustainability Data Exchange
• SAP Responsible Design and Production
• SAP Green Ledger
• SAP Business AI
• Two new AI-driven sustainability use cases: emission factor mapping with AI and ESG report generation with AI
• Additional use cases expected to be made available throughout the year

Purpose: Enable customers to drive sustainable practices within their organizations and across their value chains, embed sustainability into every aspect of operations, and meet complex sustainability regulations.

Actions as Exemplar (Own Operations)

The excerpts reference actions taken in own operations to reduce emissions, but specific action names, timelines, and resource allocations are not detailed in the provided text. The document indicates these are covered under the climate change mitigation commitment outlined above.

Stakeholder Engagement

SAP actively engages and collaborates with partners, suppliers, governments, NGOs, and investors to evolve sustainable performance along the value chain and the solutions provided to customers.

Resources Allocated

Non-financial resources:

• Dedicated business unit reporting directly to CEO
• Partnerships with customers and partners across several initiatives to contribute to UN SDGs
• Guiding principles and policies for ethical AI use

Financial resources: Not quantified in the provided excerpts.

Targets related to climate change mitigation and adaptation

Net-Zero Climate Target

Target: 1.5°C-aligned science-based target (SBTi validated)

Target metric: Gross GHG Emissions (market-based) across value chain (Scope 1, 2, and 3)

Target value: Reduce by at least 90%, which corresponds to less than 0.7 million tons CO₂e. Remaining residual emissions (maximum 10%) will be neutralized by carbon removals.

Target year: 2030 (near-term and long-term target)

Baseline year: 2023

Baseline value: 6.9 million tons Gross GHG Emissions (market-based)

Scope: Global, covering:

• GHG Protocol-aligned baseline
• Scope 1
• Scope 2 (market-based)
• All business-relevant Scope 3 value chain emissions (upstream and downstream)
• Own operations and relevant value chain

Type: Absolute target

Validation: Science-based target validated and approved by the Science Based Targets initiative (SBTi), compatible with limiting global warming to 1.5°C as advocated by the Paris Agreement

Progress to date (2024):

• Gross GHG Emissions (market-based): 6.9 million tons CO₂e (remained stable compared to 2023)
• Breakdown: Scope 1 & 2 (market-based): 0.1m tons CO₂e (2%); Scope 3 Upstream: 1.3m tons CO₂e (19%); Scope 3 Downstream: 5.5m tons CO₂e (80%)

Notes:

• SAP acknowledges that some vendors are reconsidering net-zero targets and that growing energy demand from AI may impact achievement
• SAP is monitoring progress and evaluating whether the 2030 target can be achieved as planned or requires adjustment
• Target is part of Executive Board's long-term incentive (10% of variable LTI compensation)

Zero E-Waste Target

Target: Work to achieve zero e-waste in own operations

Target metric: E-waste diverted from incineration and landfill

Target value: Divert more than 90% of electrical and electronic waste from incineration and landfill

Target year: 2030

Baseline year: The target applies to all e-waste on an annual basis, regardless of a base year

Scope: Global, covering own operations including:

• SAP-operated data centers (SAP-owned data centers and colocations)
• End-user IT equipment
• Own facilities

Type: Relative target (percentage-based)

Validation: Voluntary target defined in SAP Global Environmental Policy

Specific Reduction Goals by Category

Cloud Transformation:

• Goal: Reduce GHG emissions related to on-premise software by approximately 90% compared to 2023
• Time horizon: Ongoing until 2030

Supply Chain:

• Goal: Reduce GHG emissions related to procurement by around 90% compared to 2023
• Time horizon: Ongoing until 2030

Global Car Fleet:

• Goal: Reduce GHG emissions related to the global car fleet by more than 90% compared to 2023
• Time horizon: Ongoing until 2030
• Action: From 2025 onward, usage of vast majority of new company cars planned to be emission-free

Climate Finance Commitment (Beyond Value Chain)

Target: Annually finance climate projects that reduce and remove more CO₂ from the atmosphere than SAP's own operations (Scope 1, 2, and business travel) produce in a year

Target year: Until 2030

Progress to date (2024): Funded portfolio reducing and removing approximately 276 kilotons CO₂e (47 kilotons through direct funding, 229 kilotons through carbon credits)

Note: This is a voluntary contribution beyond SAP's value chain and does not count toward the net-zero target reduction.

Tree Planting Goal

Target: Plant 25 million trees

Target year: By 2030

Progress to date: Between 2012 and 2024, SAP's nature investments helped plant more than 20 million trees

Energy consumption and mix

Total Energy Consumption

SAP's Total Energy Consumption in 2024 was 757,900 MWh.

Energy Consumption by Source

Disaggregated Energy Consumption by Scope and Activity Type

Renewable Energy Sources – Further Disaggregation

Methodology and Scope

• Organizational boundaries: SAP applies the operational control approach as per the GHG Protocol. Energy consumption covers all operations over which SAP has operational control, including owned or leased facilities, colocation data centers, and vehicles.
• Stationary combustion: Includes gas and oil heating systems in office buildings (owned and leased), diesel in generators, and gas in co-generation/combined heat and power (CHP) systems. Wood pellets used in Walldorf CHP are classified as renewable.
• Renewable electricity: 100% of electricity consumed in offices, SAP-owned data centers, and colocations is sourced from renewable sources through a combination of self-generation (solar panels at select sites), Energy Attribute Certificates (EACs) certified by EKOenergy, and green tariffs in select locations (e.g., Australia).
• Data quality: Where measured data is unavailable, stable values (e.g., kWh/m² for buildings, liters/car for fleet) based on prior-year consumption are used for extrapolation.
• Home office electricity: Starting in 2024, home office electricity is no longer included in SAP's energy reporting due to its insignificance relative to total energy consumption and the implementation of a strict return-to-office policy.
• Conversion factors: Energy and GHG conversion factors are sourced from IEA, US EPA, UK DEFRA, Environment Canada, and the GHG Protocol, and are reviewed and updated annually.

Energy Intensity

SAP does not disclose energy intensity per revenue in the 2024 report, as it is not classified as a high-impact climate sector under ESRS.

Gross Scopes 1, 2, 3 and Total GHG emissions

Greenhouse Gas Emissions Overview

SAP reports its greenhouse gas emissions following the GHG Protocol, disclosing Scope 1, 2, and 3 emissions. The company reports Scope 2 using both location-based and market-based methods.

Gross GHG Emissions (2024 and 2023)

Note: Numbers may not sum due to rounding.

Scope 1 Breakdown

Scope 1 emissions comprise direct emissions from sources owned or controlled by SAP:

• Stationary combustion in facilities: Emissions from oil or gas combustion in heating systems and generators in SAP office buildings and data centers
• Mobile combustion from corporate cars: Emissions from company cars for which SAP covers fuel costs
• Mobile combustion from corporate jets: Emissions from SAP-owned or chartered jets
• Refrigerants in facilities: HFC emissions from cooling systems and air conditioning equipment
• Wood pellets: Biogenic CO₂ emissions from wood pellet combustion (0.4 kilotons in 2024, 0.3 kilotons in 2023) reported separately as "outside of scope"

Scope 2 Breakdown

Scope 2 emissions include indirect emissions from purchased energy:

• Electricity in office buildings
• Electricity in SAP-owned data centers
• Electricity in colocation data centers
• E-mobility: Emissions from electric company cars
• Purchased chilled and hot water, and steam (district heating)

Note on home office electricity: Starting in 2024, SAP no longer includes GHG emissions from end-user IT equipment used by employees working from home, as this consumption is insignificant compared to SAP's total energy consumption and SAP implemented a strict return-to-office policy.

Scope 3 Upstream Breakdown

Scope 3 upstream emissions include:

• Business flights: Emissions from business air travel (77% data coverage)
• Rental cars: Emissions from rental car use (75% data coverage)
• Train travel: Emissions from train travel; German train travel is carbon neutral due to Deutsche Bahn's 100% green electricity (39% data coverage)
• Business trips by private car: Emissions from employee-owned cars and company cars without fuel cards (100% data coverage)
• Flexible Mobility: Emissions from SAP's mobility budget program (100% data coverage)
• Employee commuting: Emissions from employee commuting, excluding company cars (28% data coverage based on 2022 survey with ~30,000 responses)
• Purchased goods and services: All significant cradle-to-gate upstream emissions from purchased goods and services, including waste/water disposal, hyperscale provider services, fuel- and energy-related activities, and upstream transportation and distribution. Calculated using spend-based method (100% data coverage)
• Capital goods: Cradle-to-gate emissions from purchased capital goods including buildings, data center/IT equipment, and cars (100% data coverage)

Scope 3 Downstream Breakdown

• Use of sold products: Estimated energy consumption based on productive installations with active maintenance contracts and average regional PUEs from SAP's managed colocations. Only on-premise solutions with active maintenance contracts are included; cloud solutions are excluded as they are covered in Scope 1 and 2 data center emissions (100% data coverage)

Excluded Scope 3 Categories

The following Scope 3 categories are not applicable or insignificant to SAP's operations:

• Downstream transportation and distribution
• Processing of sold products
• End-of-life treatment of sold products
• Downstream leased assets
• Franchises
• Investments
• Upstream leased assets (classified as Scope 1 and 2 following operational control approach)

GHG Intensity

GHG intensity metrics are not explicitly disclosed in the E1-8 section.

Biogenic CO₂ Emissions

Biogenic CO₂ emissions from wood pellet combustion: 0.4 kilotons in 2024 (2023: 0.3 kilotons). These are reported separately from mandatory Scope 1 emissions.

Carbon Credits and Removals

Carbon credits removed or reduced: 229 kilotons in 2024.

Calculation Methodology and Scope

Organizational Boundaries: SAP applies the operational control approach per the GHG Protocol. All operations over which SAP has operational control, including owned/leased facilities, colocation data centers, and owned/operated vehicles, are included.

Conversion Factors: Based on IEA, US EPA, UK DEFRA, Environment Canada, and GHG Protocol. Global warming potential factors follow IPCC's Sixth Assessment Report. All GHG emissions are reported in CO₂ equivalents including CH₄ and N₂O impacts.

Excluded Gases: SF₆, PFCs, and NF₃ are not included as they do not occur in SAP's operations or value chain.

Data Quality: Where measured data is unavailable, stable values from prior year data are used for extrapolation (e.g., kWh/m² for facilities, liters/car for fleet).

Scope 2 Methods:

• Location-based: Uses country-specific grid emission factors
• Market-based: Applies regional energy attribute certificates (EACs) portfolio approach

Refrigerants: All refrigerants assumed to be HFC134a; includes colocation data center server units since 2022.

Business Flights: DEFRA factors adjusted to use previous year's load factors to eliminate COVID-19 distortions. Radiative forcing not included (77% data coverage).

Energy Consumption: Total energy consumption in 2024 was 757,900 MWh (included in E1-5).

Renewable Energy: 310,000 MWh of purchased or acquired renewable electricity, heat, steam, and cooling in 2024 (included in E1-6).

Baseline and Target Context

SAP's net-zero commitment uses 2023 as the base year with 6.9 million tons (market-based) and targets at least 90% reduction by 2030 (to less than 0.7 million tons). The target is SBTi-validated and aligned with limiting global warming to 1.5°C.

Reasonable Assurance KPIs

The following metrics were subject to reasonable assurance by BDO:

• Carbon Credits
• Gross GHG Emissions (location-based)
• GHG Emissions Scope 1
• GHG Emissions Scope 2 (location-based)
• GHG Emissions Scope 2 (market-based)
• GHG Emissions Scope 3 Upstream
• GHG Emissions Scope 3 Downstream
• Renewable Energy (including certificates)
• Total Energy Consumption

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Phase-in Exemption

SAP has applied the phase-in exemption for ESRS E1-9. The following disclosure requirements related to E1-9 are indicated as "Relevant from IR25 onward":

• E1-9 Exposure of the benchmark portfolio to climate-related physical risks
• E1-9 Disaggregation of monetary amounts by acute and chronic physical risks
• E1-9 Location of significant assets at material physical risk
• E1-9 Breakdown of the carrying value of real estate assets by energy-efficiency classes
• E1-9 Degree of exposure of the portfolio to climate-related opportunities

Climate-Related Opportunities Identified

SAP has identified the following climate-related opportunities in its IRO assessment:

Climate change mitigation - Opportunity (E1-9): Customers may be exposed to fines and legal action due to not meeting external demands regarding climate change mitigation (regulatory reporting and transformation obligations, customer contract agreements) and might buy SAP sustainability products (transition risks).

• Value chain location: Downstream
• Time horizon: Medium-term, Long-term
• Impact: Potential, Indirect
• Company-specific: Not applicable (NA)

Climate change mitigation - Opportunity (E1-10): Proactive and enforced engagement in mitigation initiatives, transformation measures, and innovations (including the development of new SAP solutions) can help to make SAP more resilient, build up competitive advantage, enhance SAP's brand reputation, win new markets, increase revenues, maintain long-term viability, and reduce costs internally.

• Value chain location: Own operations
• Time horizon: Medium-term, Long-term
• Impact: Potential, Actual, Direct
• Company-specific: Not applicable (NA)

Climate change mitigation - Opportunity (E1-11): Increasing demand for software solutions tracking CO2 emissions - EHS-EM, SCT, SFM, SDX.

• Value chain location: Downstream
• Time horizon: Medium-term, Long-term, Actual
• Impact: Indirect
• Company-specific: Not applicable (NA)

Energy - Opportunity (E1-12): Energy efficiency leads to cost savings in offices.

• Value chain location: Own operations
• Time horizon: Short-term, Medium-term, Long-term
• Impact: Potential, Actual, Direct
• Company-specific: Not applicable (NA)

Transition Risks Identified

Energy - Risk (E1-13): Energy price volatility risk in own operations and our value chain.

• Value chain location: Upstream, Own operations, Downstream
• Time horizon: Short-term, Medium-term, Long-term
• Impact: Potential, Actual, Direct
• Company-specific: Not applicable (NA)

Quantified Financial Effects

No quantified financial effects (in €) are disclosed for the reporting year 2024. SAP has indicated that detailed quantitative disclosures related to E1-9 will be provided from IR25 (Integrated Report 2025) onward.

Policies related to own workforce

SAP discloses several policies and frameworks related to its own workforce, aligned with international standards including the UN Guiding Principles on Business and Human Rights (UNGPs), ILO Declaration on Fundamental Principles and Rights at Work, and OECD Guidelines for Multinational Enterprises.

Global Human Rights Commitment Statement

Scope: Global, covering SAP's own workforce and operations

Key content:

• Commitment to upholding human rights in line with UNGPs, OECD Guidelines for Multinational Enterprises, and ILO Declaration on Fundamental Principles and Rights at Work
• Support for fundamental freedoms: freedom of association and the right to collective bargaining
• Prohibition of discrimination, forced labor, and child labor
• Commitment to fair compensation and a safe and healthy work environment
• Engagement with potentially affected stakeholders both within and outside the Company
• Commitment to working with affected people or their representatives to remedy negative impacts on human rights depending on SAP's causal contribution

Public availability: Referenced in the report as publicly available

International standards linkage: Explicitly aligned with UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises, ILO Declaration on Fundamental Principles and Rights at Work

Governance: SAP's management regularly meets with employee representatives to understand concerns related to rights protected by the German Supply Chain Act

Global Code of Ethics and Business Conduct for Employees

Scope: All employees globally

Key content:

• Foundation for implementing SAP's commitment to universal human rights principles
• Covers ethical behavior and code of conduct
• Includes mandatory training for the entire SAP organization

Monitoring: Mandatory training in ethical behavior, code of conduct, and risk management conducted for entire SAP organization

Global Risk Management Policy

Scope: SAP Group-wide, all employees

Key content:

• Reviewed annually
• Stipulates responsibilities for conducting risk management activities
• Defines reporting and monitoring structures
• States that each employee is responsible for active engagement in the risk management process and continuous identification of risks

Governance:

• Executive Board responsible for ensuring effectiveness of the internal control system and risk management system
• Audit and Compliance Committee of the Supervisory Board regularly monitors effectiveness
• GR&AS organization provides status updates to the Audit and Compliance Committee

Monitoring:

• Annual review of the policy
• External auditors assess the early-warning system for risk detection annually
• External audit of effectiveness of internal controls over financial reporting

SAP Global Anti-Discrimination Statement

Key content: Referenced as a standalone policy document (listed in company policies section)

Public availability: Available on SAP website

SAP Global Artificial Intelligence Ethics Policy

Scope: All AI use cases and employees involved in AI development and deployment

Key content:

• Based on SAP's Guiding Principles for Artificial Intelligence
• Use-case-based approach to upholding AI ethics standards
• High-risk use cases reviewed by AI Ethics Steering Committee
• Any employee can report concerns through Speak Out at SAP tool

Governance:

• AI Ethics Steering Committee reviews all high-risk use cases
• SAP Executive Board reviews and ratifies Committee's recommendations for issues with wider implications
• Development, deployment, use, or sale cannot proceed if no ethically acceptable trade-off can be identified

Monitoring:

• In 2024, 41% of all relevant use cases recognized as high-risk and reviewed
• Two concerns reported to AI Ethics Office in 2024 (neither substantiated)
• Mandatory compliance training course introduced for all employees in November 2024

Public availability: Referenced as publicly available (SAP's Guiding Principles for Artificial Intelligence and SAP Global Artificial Intelligence Ethics Policy)

Workplace accident prevention policy or management system

Content: Referenced as existing in context of health and safety for own workforce (indicator number 1 Table #3 of Annex 1)

Scope: Own workforce

People Agenda

Scope: All SAP employees globally

Key content:

• Established in 2024 as a holistic system interconnecting people, organizational, and technological development
• Three key strategic pillars built on strong foundation
• Growth culture guides internal work and external customer approach
• Increases capacity for change, drives efficiency, ensures accountability

Governance: Part of SAP's corporate strategy, defined as key strategic priority

SAP confirms that at the time of publication, they are not aware of any cases of severe human rights incidents connected to own workforce that constitute a violation of the UNGP or OECD Guidelines for Multinational Enterprises.

Taking action on material impacts on own workforce

Work-Life Balance

Action description: SAP's work environment supports work-life balance through flexible work schedules, trust-based working hours, and hybrid work options.

• Impact type: Positive
• Scope: Own operations
• Time horizon: Not specified
• Resources allocated: Not disclosed
• Expected outcomes/KPIs: Not disclosed
• Policy/target linkage: Not disclosed

Health and Safety

Action description: Promote healthy behavior and well-being for employees through various programs and offerings.

• Impact type: Positive
• Scope: Own operations
• Time horizon: Not specified
• Resources allocated: Not disclosed
• Expected outcomes/KPIs: Not disclosed
• Policy/target linkage: Not disclosed

Gender Equality and Equal Pay

Action description: Improve employee performance through job satisfaction, motivation, and productivity as a result of equal opportunities and equal treatment.

• Impact type: Positive
• Scope: Own operations
• Time horizon: Not specified
• Resources allocated: Not disclosed
• Expected outcomes/KPIs: Not disclosed
• Policy/target linkage: Not disclosed

Training and Skills Development

Action description: Training and development programs at SAP help employees obtain valuable and relevant new skills and improve their career development.

• Impact type: Positive
• Scope: Own operations
• Time horizon: Not specified
• Resources allocated: Not disclosed
• Expected outcomes/KPIs: Not disclosed
• Policy/target linkage: Not disclosed

Employment and Inclusion of Persons with Disabilities

Action description: Accessibility and equality initiatives making SAP buildings, digital platforms, and training content accessible to people with disabilities, while also providing necessary accommodations and possibility to self-disclose their disability ensures equal opportunities for all employees.

• Impact type: Positive
• Scope: Own operations
• Time horizon: Not specified
• Resources allocated: Not disclosed
• Expected outcomes/KPIs: Not disclosed
• Policy/target linkage: Not disclosed

Measures Against Violence and Harassment

Action 1: Anti-Discrimination Training Course

• Description: Mandatory harassment training course (including regional legal nuances) covering all aspects of the Global Anti-Discrimination Policy. The course is mandatory for all employees (except for employees of SAP Deutschland) and is offered on an annual basis. It explains how to report incidents and the investigation process.
• Scope: Own operations
• Time horizon: Annual (ongoing)
• Resources allocated: Not quantified. Training delivered through internal learning platform globally.
• Expected outcomes/KPIs: Ambition to reach completion rate of at least 85%. For 2024, completion rate was 97.1%.
• Policy/target linkage: Global Anti-Discrimination Policy

Action 2: Preventive Training for Managers

• Description: Global People Compliance team offers preventive training courses aimed specifically at SAP managers. Offered on demand based on compliance situation in different regions, or can be requested by organizations.
• Scope: Own operations
• Time horizon: On-demand (ongoing)
• Resources allocated: Not quantified. Delivered by Global People Compliance team.
• Expected outcomes/KPIs: Not disclosed
• Policy/target linkage: Global Anti-Discrimination Policy

Action 3: Speak Out at SAP Tool and Resolver Case Management System

• Description: Reporting mechanism allowing employees to raise concerns or complaints using Speak Out at SAP tool (online or helpline). In June 2024, Global People Compliance implemented Resolver, a global case management system that allows employees to report concerns and helps manage concerns and investigations efficiently.
• Scope: Own operations
• Time horizon: Ongoing; Resolver implemented June 2024
• Resources allocated: Not quantified. Global case management system (Resolver).
• Expected outcomes/KPIs: Not disclosed
• Policy/target linkage: Global Anti-Discrimination Policy

Action 4: Support Structures for Employees

• Description: Well-defined structures put in place to support employees on topics related to discrimination and harassment, improving employees' sense of belonging, satisfaction, and trust in SAP.
• Impact type: Positive
• Scope: Own operations
• Time horizon: Not specified
• Resources allocated: Internal information available on Global People Compliance SharePoint and internal portal pages; virtual enablement sessions for HR functions
• Expected outcomes/KPIs: No targets related to this positive impact
• Policy/target linkage: Global Anti-Discrimination Policy

Diversity

Action description: Improve employee performance through job satisfaction, motivation, and productivity as a result of diversity and inclusion programs and networks.

• Impact type: Positive
• Scope: Own operations
• Time horizon: Not specified
• Resources allocated: Employee network groups (ENGs) - voluntary, employee-led diversity and inclusion initiatives formally supported by SAP
• Expected outcomes/KPIs: Not disclosed
• Policy/target linkage: Not disclosed

Targets related to own workforce

SAP discloses three gender diversity targets for its own workforce:

Target 1: Women in the Workforce (WiW)

• Target metric: Share of women in the total workforce (calculated in heads)
• Target value: 35%
• Target year: 2022
• Baseline year: 2012 (measurement started)
• Baseline value: Not disclosed
• Scope: Own workforce
• Type: Not specified (absolute percentage)
• Validation: Internal target
• Progress: Target reached before the end of 2022

Target 2: Women in Management (WiM)

• Target metric: Share of women in management positions compared to total number of managers (calculated in heads, includes three categories: managers managing teams, managers managing managers, and Executive Board members)
• Target value: 30%
• Target year: 2022 (extensions requested for 2023 and 2024)
• Baseline year: 2012 (measurement started)
• Baseline value: Not disclosed
• Prior target: 25% reached in 2017
• Scope: Own workforce (excludes employees from Taulia, Emarsys, Volume Integration, LeanIX, and WalkMe)
• Type: Not specified (absolute percentage)
• Validation: Internal target
• Progress: Did not meet the 30% target by 2022 due to unforeseen challenges; extensions requested for 2023 and 2024

Target 3: Women in Executive Roles (WiER)

• Target metric: Percentage of women in the three management levels below the Executive Board (Group Executive Level, Senior Executive Level, Executive Level) compared to total number of individuals across all genders in these levels (calculated in heads)
• Target value: Not disclosed in excerpts
• Target year: Not disclosed in excerpts
• Baseline year: 2023 (measurement started)
• Baseline value: Not disclosed
• Scope: Own workforce (excludes employees at Taulia, Emarsys, Volume Integration, LeanIX, or WalkMe)
• Type: Not specified (absolute percentage)
• Validation: Internal target; has influence on Executive Board compensation
• Progress: Not disclosed in excerpts

Characteristics of the undertaking's employees

Total Headcount and FTE

As of December 31, 2024:

Prior Year (December 31, 2023):

The report notes that overall headcount increased by 1,519 FTEs in 2024, with 607 FTE added organically. Prior year total headcount (2023) can be calculated as 109,121 - 1,519 = 107,602 FTE.

Headcount by Gender

Headcount (heads):

Full-Time Equivalents (FTE):

Headcount by Country/Region

Countries with 50+ employees representing at least 10% of total headcount:

The report notes that SAP operates across three regions: EMEA (Europe, Middle East, and Africa), Americas, and APJ (Asia Pacific Japan). However, complete regional breakdowns are not provided in the excerpts.

Headcount by Employment Contract Type

Total by contract type (headcount):

Non-guaranteed hours employees: Not applicable. SAP notes that none of its employee categories match the ESRS definition of "non-guaranteed hours employees." However, SAP has 1,548 temporary hourly-paid employees (747 male, 798 female, 2 other, 1 not disclosed) who have a reliable minimum number of hours guaranteed.

Headcount by Employment Type (Full-time/Part-time)

Not disclosed. The report notes that employees can work full-time or part-time under both permanent and temporary contracts, but does not provide a breakdown of total headcount by full-time versus part-time status.

Employee Turnover

2024:

• Employee Turnover rate: 7.8%
• Employees who left SAP: 8,390 FTE
• External hires: 8,974 FTE

2023:

• Employee Turnover rate: 6.0%

Turnover methodology: Employee Turnover describes the overall rate of terminations (employees leaving SAP, not internal transfers), including fully integrated acquisitions. It applies to headcount-relevant employees only and is calculated based on FTE numbers. The number includes all headcount-relevant employees whose employment contracts have been terminated and those who have accepted a fixed-term non-headcount relevant contract of less than six months.

Headcount by Function

As of end of 2024:

• R&D headcount: 37,590 FTE (34% of total headcount)

2023:

• R&D headcount: 36,444 FTE (34% of total headcount)

Breakdowns by other functional areas are referenced in the report but detailed numbers are not provided in the excerpts.

Non-Employee Workers

SAP employs external workers classified as "temporary staff" who are considered part of SAP's own workforce. These are persons deployed as replacement employees for limited periods. Specific headcount numbers for this category are not disclosed in the excerpts.

Methodology Notes

• Headcount-relevant employees: Generally includes all active employees on permanent contracts and employees on contracts longer than six months. Excludes students and employees on long-term leave.
• FTE calculation: Indicates staffing percentage based on capacity utilization (e.g., half-time employee = 0.5 FTE).
• Gender "other" category: Refers to gender as specified by employees themselves where legally recognized (Germany, Argentina, India as of end 2024).
• All numbers reported as of December 31, 2024 unless otherwise stated.

Characteristics of non-employees in the undertaking's own workforce

Classification and Governance

SAP's Global External Workforce Policy describes and governs worker classifications. SAP also has country-specific policies in place to cover 90% of the external worker population to ensure that specific local legislative considerations are documented clearly within those policies.

The only external worker classification that would be considered part of SAP's "own workforce" is "temporary staff."

Temporary staff are persons deployed to act as replacement employees for a limited period of time. They can be integrated into a team and given working instructions as if they were employees. Typical circumstances in which temporary workers may be engaged to replace or fill in for an SAP employee include:

• Providing cover for employees who are on extended leave (for example, maternity leave, or extended sick leave)
• Providing cover for temporary peaks in work
• Providing specialist skills on a short-term basis

Headcount of Non-Employee Workers

In 2024, SAP contracted 901 temporary staff by headcount through undertakings primarily engaged in employment activities. This figure is an average of the number of individuals engaged in 2024.

Methodology

• Counting method: Headcount (average number of individuals engaged in 2024)
• Type: Temporary staff only
• Source: Contracted through undertakings primarily engaged in employment activities

Classification of Other Non-Employees

All other non-employee engagements are classified as "services." This means that the supplier provides a service and that SAP contracts the service to be delivered, not the labor. Per the requirements of a service, the work is not under the control or supervision of SAP. For more information about workers in the value chain, see the section Workers in the Value Chain.

Access and Communication

Global communications to all employees do not usually include temporary staff, due to the dynamic nature of distribution lists for them. For local events and communication channels, local laws stipulate whether or not temporary staff should be included. Temporary staff can also access information published on SAP One, SAP's internal employee portal.

Temporary staff have access to SAP's People Compliance complaints channels, including the Speak Out at SAP tool and the Global Ombuds Office.

Collective bargaining coverage and social dialogue

Our Approach and Policies

We respect the rights of our employees to organize and to be represented by labor unions and other bona fide employee representatives in accordance with local laws, and, as such, we engage in constructive dialogue with employee representatives (see our Human Rights Commitment Statement). We have an Employee Involvement Agreement (EIA). Where local laws restrict the establishment of certain employee representations, we are open to other forms of employee representation that are not prohibited under local law.

Social Dialogue Structures

1. SAP SE Works Council (Europe)

The SAP SE Works Council (Europe) ("SE WoC (Europe)") brings together employee representatives from the 28 EEA (European Economic Area) countries (including, until May 15, 2024, the United Kingdom) in which SAP SE has subsidiaries and ensures the representation of their rights to be informed and consulted. The composition, competence, and procedures of the SE WoC (Europe) are governed by the EIA.

The EIA governs the SE WoC (Europe) rights to be informed about and consulted on matters that affect two or more countries in the EEA and specific matters such as strategy, economic and financial situation, development of business, trend of employment, investments, reorganizations, introduction of new working methods, relocation of undertakings, mergers or split-ups, cutbacks or closures, collective redundancies, changes to compensation structures, diversity and demographic trends.

The SE WoC (Europe) meets every quarter at SAP headquarters in Walldorf.

2. Global Labor Relations and HR Directors

Global Labor Relations (GLR) liaises directly with the SE WoC (Europe) and with the works councils/unions in France and Germany. In other countries, local HR directors are tasked with liaising with employee representatives.

Metrics on Material Topics

Collective Bargaining Agreements and Social Dialogue Coverage

In 2024, 36% of SAP employees were covered by collective bargaining agreements.

In the EEA, SAP had 262 collective bargaining agreements. Outside the EEA, 5% of our employees were covered by collective bargaining agreements.

50% of our employees globally were covered by workers' representatives.

Breakdown of collective bargaining coverage and workplace representation by country/region:

Our Actions and Targets

Diversity metrics

Gender distribution in workforce

Definitions:

• Women in Workforce (WiW): Share of women in total workforce (calculated in heads)
• Women in Management (WiM): Share of women in management positions compared to total number of managers (individuals, not FTEs). Includes: 1) Managers managing teams; 2) Managers managing managers; 3) Executive Board members
• Women in Executive Roles (WiER): Percentage of women in the three management levels below the Executive Board (Group Executive Level, Senior Executive Level, Executive Level), calculated in heads

Scope exclusions: WiM and WiER do not include employees from Taulia, Emarsys, Volume Integration, LeanIX, and WalkMe

Age band distribution of total workforce (2024)

Note: Does not include employees at Taulia, Emarsys, Volume Integration, LeanIX, or WalkMe

Disability metrics (2024)

In countries that permit the collection of disability data, the proportion of workforce that self-identifies as having a disability is 1.3%.

Gender breakdown of employees with disabilities:

• Women: 39.2%
• Men: 60.8%

Note: SAP has legal entities and employees in 73 countries; the disability self-identification project is currently implemented in 43 countries where legally possible.

Adequate wages

Benchmark used

SAP states that all employees are paid an adequate wage. The company ensures that all employees are paid at least the minimum wage mandated by local laws. In regions without a legally defined minimum wage, or in the event that living wages are above the legally defined minimum wage, SAP adheres to the living wage standards.

The data for defining living wage is provided by the external organization "Valuing Impact" in collaboration with "WageIndicator", as used by the Value Balancing Alliance (VBA) methodology.

Coverage

The adequate wage analysis covers all employees at SAP, regardless of specific personal criteria such as gender or age.

Exclusions: The adequate wage coverage does not include employees at Taulia, Emarsys, Volume Integration, LeanIX, or WalkMe.

Policy framework

SAP's Global Policy on Compensation Management details the frameworks and principles in place to ensure fair and adequate wages for employees. SAP uses a total target cash (TTC) approach with base salary and target bonus. The policy is connected to SAP's global job architecture and salary structures are reviewed at least once a year and adjusted to maintain market alignment.

Monitoring and targets

Adherence is monitored through two annual analyses:

1. Pay within the pay range (ensuring all employees are paid within their designated pay range)
2. Assessment of pay equity within ranges (ensuring equitable pay relative to similar peers)

SAP adjusts an individual's TTC if it falls below the recommended minimum or acceptable spread relative to peers.

Target: In 2022, SAP began making annual global pay adjustments to ensure that the compensation of at least 99% of employees is within their pay ranges and equitable among comparable peers. SAP reports it is meeting that target (using data after annual adjustments). In addition, SAP has met its target of 99.9% pay range transparency.

SAP is targeting a full action plan in relation to the EU Pay Transparency Directive by 2026.

Value chain

For value chain workers, SAP's Supplier and Partner Codes of Conduct require suppliers to uphold human and labor rights. SAP identifies "suppliers not paying their employees a decent living wage" as a material potential negative impact. SAP conducted an analysis to identify areas requiring greater attention and is discussing findings with internal teams to define further action. However, specific coverage percentages or targets for value chain adequate wages are not disclosed.

Methodology

The living wage data is provided by Valuing Impact in collaboration with WageIndicator, as used by the VBA methodology. SAP's compensation investment strategy takes a "fair pay first" approach, with top priority given to pay adjustments to bring all employees into correct pay ranges.

Social protection

Coverage of employees

All permanent employees are covered by social protection, through public programs, and/or through benefits offered by SAP, against loss of income due to any of the following major life events: including, but not limited to, sickness, employment injury, and acquired disability, parental leave, and retirement.

Coverage: 100% of permanent employees

Scheme type: Public programs and/or SAP benefits

Events covered:

• Sickness
• Employment injury
• Acquired disability
• Parental leave
• Retirement

Exclusions

Coverage for temporary and hourly-paid employees in some countries may differ based on local regulations (examples include China, India, and Singapore).

Unemployment has not yet been included in this year's analysis but will be included starting next year.

Family-related leave

All permanent employees are entitled to at least one of two types of family-related leave (parental leave and family care leave). Moreover, 86% of permanent employees are entitled to both types of leave, and 22% of employees make use of them, of which 58% are male and 42% female. This breakdown is reflective of current gender demographics and includes only those countries where both types of leave are available.

Persons with disabilities

Approach and Policy

SAP strives to ensure all employees feel equally valued, including persons with disabilities. SAP achieves this through:

• Infrastructure and digital accessibility: Removing barriers supports accessibility in the workplace for people with and without disabilities
• Flexibility: An integral part of SAP's People Agenda, including flexible work models such as hybrid work
• Inclusive design methodology: Developing SAP products that work for the widest possible range of human diversity
• Product and facility accessibility: Ensuring everyone, including people with disabilities, can utilize SAP software and that buildings and facilities are fully accessible
• Anti-discrimination: Prevention through SAP Global Anti-Discrimination Policy
• Assistive technology: SAP makes a range of assistive devices and accessible technology available to employees who request them
• Global accessibility inspections: The Global Real Estate & Facilities team conducts annual global accessibility inspections and updates buildings with barrier-free infrastructure as needed

Methodology and Scope

SAP started rolling out a global disability self-identification project for countries where this is legally possible.

Scope limitations:

• SAP has legal entities and employees in 73 countries
• The project is currently implemented in 43 countries
• The European General Data Protection Regulation considers health-related data as sensitive personal data
• It is not possible to collect disability information in countries that do not have specific legislation mandating or strongly recommending such practice
• 30 countries are excluded from disability data collection due to legal restrictions

Data collection method: Self-identification by employees in countries where legally permissible

The disability metrics presented include gender breakdown and are part of this global data collection project.

Coverage

The diversity and inclusion narrative covers SAP's entire workforce, including temporary staff and interns, and is overseen by the chief diversity & inclusion officer.

Metrics

No quantitative percentage or headcount metrics for employees with disabilities are disclosed in the provided excerpts.

Training and skills development metrics

Average training hours per employee

For 2024, the average number of training hours per employee was 28 hours.

Breakdown by gender:

Note: Calculated based on active headcount-relevant employees only, using FTE. Includes formal training and mandatory and compliance training.

Breakdown by employee category: Not disclosed.

Training participation and volume

• Participation rate: 97% of employees participated in learning activities in 2024
• Total learning hours: More than 3 million learning hours in 2024
• High-intensity learners: 13,025 individuals spent more than 50 hours learning

Performance and career development reviews

Percentage of employees who had at least two SAP Talks (performance conversations) in 2024:

Additional performance review metrics:

• Average number of SAP Talks per employee: 5 (female: 5, male: 6)
• Total number of SAP Talks held in 2024: 533,952

Note: SAP Talks are dedicated conversations between employees and managers to review goals, discuss feedback, and reflect on progress, held at least twice a year (midyear and year-end).

Additional learning effectiveness metrics

• Percentage of leaders who completed at least one relevant learning asset: 36%
• Percentage of global senior executives who completed relevant development offerings: 90%
• Percentage of new hires who feel a sense of belonging after six months: 95%
• Percentage of Catalysts who believe program offerings support their development: 75%
• Vocational/Student Training conversions: 482 (71% conversion rate)

Total investment in training

Not disclosed in monetary terms. The document notes that learning expenses are split across corporate functions and can be found across different expense line items in the Consolidated Income Statements.

Health and safety metrics

Coverage of health and safety management system

SAP's health and safety management system, "Run Healthy," is based on ILO standards and is executed at local level by a local health and safety management council. The program currently covers 37% of the workforce (as of December 2024). SAP is aiming for global reach and is expanding the program step by step. Its goal is to have 100% of the workforce covered by 2027.

Fatalities and work-related accidents

SAP does not disclose specific metrics on fatalities, recordable work-related accidents, injury rates, or days lost to work-related injuries in the excerpts provided. The company notes in the ESRS datapoint table that:

• S1-14 Number of fatalities and number and rate of work-related accidents: Not material as SAP is an enterprise software company
• S1-14 Number of days lost to injuries, accidents, fatalities, or illness: Not material as SAP is an enterprise software company

SAP states: "As an enterprise software company, SAP does not have the occupational health and safety issues associated with manufacturing or heavy-industry jobs. Most of our people have sedentary, intellectually demanding jobs in a constantly changing business environment."

The company does not have a global workplace accident prevention policy or management system in place, though local workplace accident prevention programs exist in several SAP locations around the globe.

Work-life balance metrics

Family-Related Leave Entitlement and Take-Up

Entitlement to family-related leave:

• 100% of permanent employees are entitled to at least one of two types of family-related leave (parental leave and/or family care leave)
• 86% of permanent employees are entitled to both types of leave (parental leave and family care leave)

Take-up rate:

• 22% of employees entitled to both types of leave made use of them
• Gender breakdown of those who took family-related leave:
  • Male: 58%
  • Female: 42%

Scope and notes: The breakdown is reflective of SAP's current gender demographics and includes only those countries where both types of leave are available. In countries where family care leave is not yet available, SAP is committed to addressing the gap to ensure consistent access for employees globally.

Parental leave is applicable when a child joins a parent to form a family unit (as a result of birth, adoption, or legal guardianship) and includes primary caregiver and secondary caregiver leave.

Family care leave provides employees with time off to care for a family member who requires care or support for serious medical reasons.

Return-to-work rate after parental leave: Not disclosed.

Multi-year comparison: Not disclosed for 2024. No prior year data provided in the excerpts.

Compensation metrics (ESRS S1-16)

Pay gap

SAP defines the unadjusted gender pay gap as the difference in average pay levels between female and male employees, expressed as a percentage of the average pay level of male employees. Pay levels are calculated using total target cash on a full-time basis, which includes both base salaries and target bonuses as of December 31, 2024, to ensure an accurate representation. The calculation also includes long-term incentives (LTI), valued at grant date, that were granted to individual employees during the reporting year. This does not include employee share purchase plans and corresponding cover plans.

In 2024, the unadjusted gender pay gap was 20%. SAP attributes this largely to the effects of the company's demographics, including the ratio of male to female employees across seniority levels, the types of roles offered, and the geographies employees work in.

SAP used established statistical methods to account for the effects of demographic attributes that are commonly used for gender pay gap adjustments, including amongst others the distribution of employees across functional roles, seniority levels, and geographies. Applying these variables, the adjusted gender pay gap was 5%. SAP is committed to narrowing this gap and continues to make improvements in gender diversity across all levels globally.

Remuneration ratio

In determining the annual total remuneration ratio, SAP utilizes the total target cash on a full-time basis, which includes both base salaries and target bonuses as of December 31, 2024. This approach ensures that the compensation of part-time employees is accurately reflected. The calculation also includes the LTI that has been granted to individual employees during the reporting year, valued at grant date. This does not include employee share purchase plans and corresponding cover plans.

To calculate the annual total remuneration ratio, SAP first identifies the employee with the median compensation, including Executive Board members, but excluding the highest-paid employee. For a more comprehensive analysis, SAP also incorporates benefits for the median employee, as well as for five employees above and below the median. These 11 data points are then averaged to calculate the remuneration of the median employee and compare it with the highest-paid employee.

For the year 2024, the annual total remuneration ratio was 87 (highest-paid to median). SAP notes this is one of the lowest ratios when compared to CEO pay for other megacap multinational technology companies (as disclosed in their latest Form DEF 14A proxy statements) with whom SAP competes for talent.

Incidents, complaints and severe human rights impacts

Complaints Filed Through Grievance Mechanisms

In 2024, complaints were filed through SAP's various complaints mechanisms:

• 445 complaints filed by e-mail
• 116 complaints filed in Speak Out at SAP tool
• 438 complaints filed in Resolver

Investigations Conducted

SAP conducted a total of:

• 107 investigations into discrimination
• 447 investigations into harassment:
  • 362 investigations into psychological harassment
  • 85 investigations into sexual harassment

The number of investigations that were substantiated as policy violations was substantially lower than the total number of investigations.

Severe Human Rights Impacts

At the time of publication of this report, SAP is not aware of any cases of severe human rights incidents connected to our own workforce that constitute a violation of the UNGP or the OECD Guidelines for Multinational Enterprises.

No cases of non-compliance with the UNGPs, ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises involving value chain workers were reported in 2024.

Complaints to National Contact Points

At the time of publication, no complaints had been filed to National Contact Points for OECD Multinational Enterprises.

Fines, Penalties and Compensation

No information on fines, penalties or compensation related to incidents was disclosed.

Status of Complaints

No information on the status of complaints (open/resolved/under investigation) was disclosed.

Complaints Management Process

SAP has established a complaints management and investigations procedure that provides a globally consistent and comprehensive approach to effectively managing concerns related to potential or actual violations of human rights or environmental standards in accordance with the German Supply Chain Act.

Global People Compliance closely reviews the facts collected during each investigation to determine which measures are required to minimize violations. As part of the investigation process, the team follows up with the affected employee in an appropriate timeframe after the investigation has ended to check whether they are experiencing any additional issues.

Once a quarter, SAP analyzes regional specifics with respect to reported concerns and investigated violations of the SAP Global Anti-Discrimination Policy and implements additional preventive training measures for specific target groups at the respective locations.

Incidents of corruption or bribery

Confirmed incidents

No confirmed incidents of corruption or bribery were reported for the year 2024. SAP states: "At the time of publication of this report, we are not aware of any cases of severe human rights incidents connected to our own workforce that constitute a violation of the UNGP or the OECD Guidelines for Multinational Enterprises."

Convictions and fines

2024: There were no convictions for the violation of anti-corruption and anti-bribery laws in 2024.

Settlement in January 2024 (relating to prior years): In January 2024, SAP entered into a final settlement agreement with the U.S. Securities and Exchange Commission (U.S. SEC) and the U.S. Department of Justice (U.S. DOJ), as well as with authorities in South Africa, to resolve criminal and civil claims relating to investigations into non-compliance with SAP's policies and procedures or applicable laws in recent years. Under this agreement, SAP was required to make payments amounting to €207 million. SAP fully cooperated with law enforcement authorities and took immediate consequence management steps, including terminating the employment of all those implicated in potential law violations and terminating partner contracts. SAP entered into a three-year self-monitorship under a deferred prosecution agreement (DPA) with the U.S. DOJ.

Settlement in December 2024 (Brazil): In December 2024, SAP's Brazilian subsidiary reached a settlement with the Office of the Comptroller General of the State of Minas Gerais (CGE) and the State of Minas Gerais Public Prosecutor's Office (MPMG) in Brazil. SAP fully cooperated with the CGE and MPMG, applied appropriate consequence management, and enhanced its compliance program. SAP Brazil entered into a leniency agreement with CGE that requires SAP Brazil to continue cooperating with the authorities' investigations, and agreed to a one-year self-monitorship.

Disciplinary actions

During the investigations that culminated in the January 2024 settlement, SAP took immediate steps to discipline the employees involved, including terminating the employment of all those implicated in potential law violations. The specific number of employees dismissed or disciplined is not disclosed.

For the Brazil settlement, SAP applied appropriate consequence management, though specific numbers are not provided.

Contracts terminated

SAP terminated partner contracts in connection with the investigations leading to the January 2024 settlement. The specific number of contracts terminated is not disclosed.

Speak-up mechanisms and investigation procedures

Speak Out at SAP: SAP operates an independently managed whistleblower reporting tool called "Speak Out at SAP," available 24/7 both internally to SAP employees and externally to concerned parties, including customers, suppliers, and partners. The tool is available in multiple languages (61 languages) and allows individuals to submit reports either directly through an Internet-based portal or by phone, with the option to report anonymously if desired. SAP maintains a strict non-retaliation policy.

In 2024, 445 complaints were filed by e-mail, 116 in the Speak Out at SAP tool, and 438 in Resolver (a new global case management system launched in June 2024).

Investigations: The Office of Ethics & Compliance (OEC) has an independent and autonomous investigation team comprised of dedicated investigators who probe allegations of misconduct. All allegations and concerns are subject to appropriate in-depth examination or investigation. Where appropriate, the OEC engages the assistance of external law firms to investigate certain allegations.

SAP conducted a total of 107 investigations into discrimination and 447 investigations into harassment (362 into psychological harassment, and 85 into sexual harassment) in 2024. The number of investigations that were substantiated as policy violations was substantially lower than the total number of investigations.

Human rights-related complaints: With regard to potential human rights concerns and incidents involving upstream and downstream value chain workers, one grievance was noted in 2024, but it was not identified as severe.

Compliance program enhancements: Since the allegations were first made, SAP has significantly strengthened its compliance program and related internal controls in accordance with DOJ and regulatory expectations and requirements. SAP's CEO and CFO are responsible, together with the Group Chief Compliance Officer (GCCO), for ensuring that the requirements of the DPA are met.

Political influence and lobbying activities

Political engagement approach

SAP screened political engagement as part of its materiality assessment process in 2024, consulting internal experts from Government Affairs to identify potential impacts, risks and opportunities (IROs).

The materiality assessment evaluated political engagement in the context of SAP's business activities, taking into account location, activity, sector, and structure of transactions.

Material impacts, risks and opportunities

SAP did not identify any material IROs relating to political engagement. The company states it has robust policies in place governing political engagement and these policies are strictly enforced.

As the screening sufficiently covered the topic, SAP did not consult any external experts on political engagement matters.

Payment practices

Standard contractual payment terms

Payment terms and conditions vary by contract type and region. SAP's terms typically require payment within 30 to 60 days.

Materiality assessment

SAP did not identify any material impacts, risks and opportunities (IROs) relating to payment practices. SAP has robust policies in place governing payment practices; these policies are strictly enforced. As the screening sufficiently covered the topic, SAP did not consult any external experts.