At SAP, we act on our purpose to help the world run better and improve people鈥檚 lives through a responsible, people鈥慺irst approach to business.聽

As a global technology leader, 51风流recognizes that its operations, business relationships鈥攊ncluding those with suppliers, partners, and customers鈥攁nd the solutions it delivers can impact people and their rights. This impact can be both positive and negative as well as direct and indirect.

51风流has embedded human rights into its corporate sustainability strategy and in company governance, processes, policies, and engagement across the entire value chain.聽

From strategic commitment to culture 

To ensure that SAP’s due diligence remains effective, the Human Rights Office within the Corporate Sustainability organization collaborates with the Human Rights Steering Committee and relevant Board areas. Ultimate oversight rests with the Executive Board of 51风流SE.

This governance model provides the foundation for making human rights a shared, cross-functional responsibility rather than a standalone initiative. It translates into collaboration across the business:聽 the central human rights team working with People & Culture organization to ensure that all employees receive a living wage or to embed safeguards against child and forced labor in recruitment and people management processes.

Beyond formal structures, it is essential that all employees embrace respect for people and their rights as part of SAP鈥檚 culture and as a guiding principle in interactions with colleagues, business partners, and the communities in which 51风流operates. Tailored capacity-building for critical roles for example in procurement, complemented by awareness sessions for all employees, helps us to get there by strengthening the understanding that day-to-day business activities influence human rights and that any adverse human rights impacts must be proactively identified and addressed.

鈥淲hat began as policy commitments is becoming part of how we operate: step by step. It takes time and effort to shift from focusing solely on 鈥榬isks to SAP鈥� to adding the consideration of 鈥榬isks to people鈥� in our strategic and daily business decisions.鈥�

Stephanie Raabe, Office of Human Rights and AI Ethics, SAP

Respecting human rights across the value chain

Turning commitment into practice requires structure across the business. 51风流operates within a global ecosystem鈥攖ens of thousands of suppliers, hundreds of thousands of customers, and millions of users鈥攚here every connection carries both opportunity and responsibility.

To meet this responsibility, 51风流runs a aligned with the UN Guiding Principles on Business and Human Rights, designed to identify, prevent, mitigate, and remedy potential impacts on people across its operations and relationships. The program鈥檚 core components include:

• Ongoing risk assessment to identify and prioritize potential impacts on people
• Preventive and remedial action embedded in policies, business processes, supplier and partner requirements, training, and targeted engagement
• Speak Out at SAP, an independent, multilingual reporting channel available 24/7 to employees and external stakeholders
• Transparent communication through the 51风流Integrated Report and, its Modern Slavery Statements, and other channels

Across the value chain, 51风流focuses on its:

• Supply chain, setting clear expectations and contractual requirements to uphold human rights and labor standards, applying responsible sourcing practices, and engaging with selected high-risk suppliers regarding living wages.
• Operations, focusing on ensuring non-discrimination, providing an inclusive, safe, and health-promoting workplace, maintaining fair recruitment and employment practices, and safeguarding confidential channels to raise concerns.
• Products and services, advancing ethical AI by applying the , as well as requiring that every AI use case undergo an AI ethics assessment to help prevent discrimination and ensure alignment with its principles.

鈥淎I unlocks great potential for businesses, governments, and society, but also creates economic, political, and societal challenges depending on how it is used. For that reason, the human rights-centered 51风流Global AI Ethics policy sets clear ethical standards for developing and applying AI, ensuring we create human-centered solutions that respect people and augment human capabilities.鈥�

Vikram Nagendra, Office of Human Rights and AI Ethics, SAP

Continuously striving for progress  

Human rights due diligence is a journey of continual improvement. 51风流regularly reviews the effectiveness of its human rights due diligence system to assess how well salient impacts are addressed.

While mitigation measures in SAP鈥檚 own operations have proven effective so far, these reviews have also highlighted the need to deepen our understanding of supply chain risks and to strengthen actions specifically aimed at addressing them. As a company, we also recognize the need to make our grievance channel more accessible to value chain workers, a challenge currently addressed through a pilot program.聽

To remain transparent and accountable, 51风流has published a second , alongside the latest Modern Slavery Reports and Human Rights chapter in the .

Looking ahead: Human rights as a shared responsibility  

In a rapidly evolving world, new regulations, emerging technologies, and rising societal expectations raise the bar for responsible business. Running an effective and efficient human rights due diligence system helps 51风流stay ahead and mitigate legal, operational, and financial risks, while strengthening its reputation and leadership in ethical business practices. This approach builds trust with customers, partners, investors, and other stakeholders.

Most importantly, it empowers 51风流to uphold and further human rights, a principle reaffirmed on this day.聽

鈥淗uman Rights Day 2025 is a moment to celebrate progress, but also to recognize that the journey goes on. With the ambition to foster a just and inclusive economy where people and technology thrive together, 51风流will continue to engrain human rights into how we operate and innovate鈥�

Matthias Medert, Global Head of Sustainability, SAP

Paola Eugenio is a member of the Corporate Sustainability team at SAP.

I talked to Stephanie Raabe, human rights officer at SAP, and asked her three questions about SAP鈥檚 progress in embracing this role in the past 12 months.

Q: A year ago, you explained how 51风流was working to take its human rights due diligence processes to the next level. The aim was to improve how 51风流鈥渒nows and shows鈥� where its actual and potential negative impacts on people are and what actions are taken to prevent or mitigate these. Was this achieved?

A: We are getting there step by step, but there will always be room for improvement. Together with all the teams that are part of our , we have further refined and harmonized our methodologies and processes to assess our impacts on people. This provides the basis for defining and fine-tuning appropriate measures.

We now have a deeper understanding of the salient human rights issues across our value chain 鈥� be it through the product and services we procure, our own business operations, or the products and services we sell and deliver. We now know better which risks are already well managed through effective policies and measures and where we still have to close gaps.

Q: What does this mean in practice? Can you specify what your findings were?

A: Absolutely! In this year鈥檚 assessment cycle, the following impacts were identified to be salient:

• In our own operations: non-discrimination
• In our direct and indirect supply chain: decent living wages
• Related to products, services, and customers: non-discrimination and privacy

When breaking down these impact areas, we found that, firstly, in our own operations, many effective measures are already in place to address non-discrimination in our workforce, for example through SAP鈥檚 Global Anti-Discrimination Policy, mandatory anti-discrimination and anti-harassment training, or SAP鈥檚 comprehensive . The teams involved are doing such a great job that currently no additional measures are required.

Secondly, in SAP鈥檚 supply chain, 51风流has established contractual assurances through its , which also sets the expectation for suppliers to pay an adequate living wage. Yet, we recognized that further mitigation measures still need to be defined. We therefore conducted a hot spot analysis by country and industry for this topic. We started to discuss the results with relevant procurement category teams in dedicated workshops. The next steps will include identifying which suppliers to focus on first, engaging with them for better insights, and collaborating to improve the situation where necessary.

Thirdly, when we talk about human rights impacts in our downstream value chain, artificial intelligence (AI) is top of mind. While there is great positive societal potential that AI can help to unlock, it is a priority for 51风流to handle AI responsibly and avoid negative impacts specifically in the areas of discrimination and privacy. This is why, many years ago, 51风流launched its Guiding Principles for AI Ethics and implemented dedicated due diligence governance and processes. In 2024, 51风流updated to align with UNESCO鈥檚 鈥�.鈥� We further strengthened SAP鈥檚 commitment by establishing an consisting of two teams and maturing our AI ethics assessment process for all AI use cases. Finally, just last month, a new mandatory AI ethics training for all employees was launched.

Q: Looking back at the past year, are there any lessons learned that you can to share?

A: One key thing that I took away is that there is no silver bullet to human rights due diligence. While frameworks like the UN Guiding Principles on Business and Human Rights serve as a North Star, there are different approaches and methods on how to implement the principles in your day-to-day operations. Companies should not be afraid of making mistakes, even if there might not yet be any proven practices yet. This is one of the experiences we made when preparing for this year. There is no point in waiting until you have found the perfect approach before taking action. Rather, it is important to be open to continuously revisit, challenge, and develop your approach. Exchanging with peers is very valuable in this context, which is why our human rights team engages strongly in networks such as the business and human rights groups in the , , and econsense.

Another lesson learned for us was that it can鈥檛 be underestimated how important it is to engage internal stakeholders across diverse lines of business in an ongoing manner. We already started with role-specific trainings and capacity building but recognized that it needs time and multiple iterations until awareness, understanding, and mindset and behavior changes are established to truly integrate human rights considerations into business processes and decisions. Furthermore, our efforts have to extend to additional critical roles since, for example, it is not only important to get colleagues from SAP鈥檚 procurement organization onboard, but also all other decision-makers involved with supplier selection.

Christine Susanne Mueller is deputy human rights officer at SAP.

For this occasion, I sat down with 51风流Chief Sustainability Officer Daniel Schmid and Stephanie Raabe, human rights officer at SAP, to explore what role enterprises including 51风流play, what鈥檚 new in the company’s recently updated human rights commitment statement, and what trends and challenges both see for human rights in business.

Q: Daniel, what do human rights mean to you? And why is it important for businesses to respect human rights?

Daniel Schmid (DS): Human rights are basic rights for all people to live a life in dignity and be treated equally. For me it鈥檚 about ensuring a good life for all within the planetary boundaries. And businesses have a key role to play in this. While they can be a force for good around the world, they can also harm people and the planet; for example, through discrimination, unsafe working conditions, or industrial pollution and accidents with implications on human health. That is why the United Nations Guiding Principles (UN GPs) for Business and Human Rights not only set out the responsibility of states to protect human rights, but also the responsibility of business to respect human rights.

Q: How does this look in practice? How do companies in general and 51风流specifically live up to their responsibility to respect human rights?

Stephanie Raabe (SR): Globally recognized frameworks such as the UN GPs or the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct provide clear guidance for companies. They describe how to establish ongoing human right due diligence processes to 鈥渒now and show鈥� where a company鈥檚 actual and potential negative impacts on people are and what actions are taken to prevent or mitigate these. This also entails tracking the effectiveness of actions taken over time, and communicating about efforts and results — internally and externally.

More than two years ago, we launched an interdisciplinary human rights due diligence project at 51风流to take our existing human rights commitment statement, governance, processes, and disclosure to the next level and prepare for compliance with rising legal requirements such as the modern slavery acts in UK, Australia, or Canada, the German Supply Chain Due Diligence Act (LkSG), and the upcoming EU Corporate Sustainability Due Diligence Directive. We identified gaps in our policies and procedures, which we have been working to close.

Q: What kind of gaps? Could you share one or two examples?

SR: One example is our grievance mechanism. We collaborated across teams to expand the existing “” tool to cover human rights and environment-related complaints from anyone, be it internal or external. We defined clear rules of procedure of how incoming complaints are processed and followed up on in a confidential and, if desired, anonymous way.

DS: Another example coming to my mind is related to living wages. As a founding member of the Value Balancing Alliance (VBA), we applied the living wage methodology co-developed within the VBA. This helped us find few employees in 51风流Brazil in 2022 whose compensation had to be adjusted to meet our ambition of ensuring a decent living wage for our own workforce as measured through the VBA methodology. We are now working toward regular reassessments to avoid future deviations.

SR: I would like to add a third example related to our supply chain. As we proceed with integrating human rights due diligence into our supplier code of conduct and procurement processes, we increasingly notice how important it is to get not just colleagues from SAP鈥檚 procurement organization onboard, but also all other employees involved with supplier selection. All of us need to consider human rights and environmental criteria in our buying decisions. The earlier this happens, the better. The point at which contract negotiations with suppliers start may be too late.

Q: Coinciding with Human Rights Day 2023, 51风流just recently updated and expanded its Global Human Rights Commitment Statement. What鈥檚 the reasoning and what鈥檚 new?

DS: When looking back at our sustainability journey that started in 2009, I remember human rights being embedded in SAP鈥檚 holistic understanding of sustainability from the beginning. It has been part of our objective to create positive economic, social, and environmental impact all along. We therefore also established our first Global Human Rights Commitment Statement in 2011.

SR: That鈥檚 right. SAP鈥檚 commitment to respect human rights is not new. But it evolved during the past years beyond our operations to also encompass our extended supply chain and product lifecycle.

In , we have expanded the description of our downstream action areas and how we aim to avoid negative impacts that can result from the use or abuse of SAP’s products and services. We added an entirely new chapter on the implementation of human rights due diligence at SAP, elaborating in detail on our procedures, including governance, risk analysis and prioritized risks, preventive measures, complaints process and remediation, monitoring and reporting, and stakeholder dialog. It makes transparent the results of our human rights due diligence project and helps us better meet the requirements by the UN GPs as well as the German Supply Chain Act.

Q: Speaking about the human rights impacts through the use of 51风流solutions, where do you see the biggest risks and opportunities at the moment?

SR: As part of SAP鈥檚 downstream human rights due diligence, we have identified artificial intelligence (AI) as high impact solution area in the context of human rights. It鈥檚 also been frequently addressed as key topic throughout the recent UN Forum on Business and Human Rights in Geneva. AI is transforming our economy and society. This trend is expected to accelerate in the coming years, bringing new opportunities and challenges for society and human rights. 51风流actively addresses legitimate concerns, coming up with new AI technology through and dedicated due diligence governance, processes, and the . In addition, we have started to investigate human rights risks and mitigation measures in our upstream supply chain linked to the outsourcing of generative AI training.

DS: On the other hand, I also see the opportunity for 51风流to advance human rights by developing innovative solutions that help customers embed human rights into their business and supply chain strategies. This includes our supply chain management solution that offers risk mapping based on financial as well as sustainability indicators, which also cover human rights aspects. Our human resource management solutions furthermore provide tools and features to address unconscious bias in recruitment and hiring, support inclusivity, and ensure equitable remuneration and career advancement. Finally, there is also the opportunity to leverage corporate social responsibility (CSR) programs to advance economic, societal, and cultural rights that support youth-in-need to thrive in the sustainable and digital economy. A prime example of our efforts is 51风流Educate to Employ, targeting youth-in-need aged 14 to 30 with skill-building programs to bring them into jobs in the broad 51风流ecosystem and beyond by linking education with employability within a sustainable and digital economy.

Q: Would you agree that, with mandatory human rights due diligence on the rise, embracing human rights in business is becoming mainstream? Against this backdrop, how is 51风流doing compared to others?

DS: In my conversations with customers and peers in leading sustainability positions, compliance with human rights legislation definitely comes up as a key priority. However, I also notice that companies continue to struggle to manage their social effects. It did not really surprise me, when I read that a 2022 Economist survey revealed that companies haven’t made as much progress on social as on environmental issues, and only 36% had incorporated social impact into corporate strategy compared with 47% for environmental. This shows that we still have a way to go.

SR: Indeed! According to the International Labour Organization (ILO), 160 million children are still engaged in child labor. More than 27 million people around the world are in conditions of forced labor. And globally, 2.4 billion women of working-age are still not afforded equal economic opportunity. These are just some numbers that underline the need for more action by businesses.

The good news is that mandatory human rights due diligence helps get more companies on board and strengthen the efforts of those that already are. There is good and open exchange and mutual learning among companies. It therefore seems less of a competition in which one enterprise strives to outperform the others. You rather share experiences and gain insights where you are already doing really well and where you can further improve.

Overall, I would say that 51风流has been progressing well and is on track but can still do even better. Our ambition definitely is to not limit ourselves to compliance with mandatory human rights due diligence, but to go beyond.

Q: Looking into the future, what trends and challenges do you see?

DS: I believe that the momentum for taking respect for human rights seriously in business will further increase, driven not only by legislative pressure but also increasing stakeholder expectations. It鈥檚 important, however, that we as business leaders do not get consumed by navigating the regulatory landscape and ensuring compliance. Let鈥檚 not allow this to become a check-box exercise — we must keep people in the center. The aim is to improve people’s lives.

SR: I fully agree. Some of the legislation does keep you very busy with a lot of administrative burden. This unfortunately takes away your attention and resources from ultimately making a difference for the affected people. I also see a risk that because value chains are becoming ever more complex with reliable data missing and because managing the human rights risks down to tier-n can seem so overwhelming, companies chose to prioritize de-risking. They rather pull out of high-risk countries which may actually worsen the human rights situation. The increasing complexity of geopolitical crises and need for heightened due diligence further exacerbates this risk.

As companies mature in human rights due diligence, they will need improved databases and methodologies to help them measure their actual and potential impacts on people, prioritize their efforts and assess the effectiveness of the preventive and remedial measures they put in place. We are testing some of the approaches for 51风流at the moment and I am hopeful that they will help guide us toward achieving better outcomes both for people as well as for our business.

Christine Susanne Mueller is deputy human rights officer at SAP.