SAP SE

Country

Germany

Headquarters

Germany

Sector

Information Technology

Performance band

E-

Total Score

Organisation Score

Relationship Score

Engagement Intensity

Theme 1 - Human rights due diligence

Businesses identify, assess, prevent, and address human rights risks within their operations and supply chains

Theme score

Q1.1 Legal DD as requirement 25

Q1.2 Legal DD for all companies -

Q1.3 Enforcement mechanism -

Q1.4 Directors and company duties -

By Legislation

Omnibus Not Supporting

Evidence for Q1.1

Making human rights due diligence a legal requirement for companies including systems to identify, assess, mitigate or manage human rights risks and impacts to improve that process over time and to disclose the risks and impacts, the steps taken and the results.

SAP response to Evian letter outreach (Legislation: Omnibus)

Legal DD as requirement

Score -1

Region

Year

2025

External Link

Data Source

Media Reports

Social LobbyMap Comment

SAP has stated they are not aligned with the Evian Letter call to abolish the CSDDD, citing why the CSDDD is important. SAP does however call for revision and simplification of the directive stating a need for it to be "workable for businesses".

Extract from Source

"SAP is aware of the letter shared by the CEOs of TotalEnergies and Siemens following the Evian Summit which was not aligned with SAP. We agree with the broader call for greater regulatory coherence, boosting EU competitiveness, and the need for a revision and simplification of the Corporate Sustainability Due Diligence Directive (CSDDD).The directive is a crucial step toward harmonized rules and a level playing field for responsible business conduct across the EU and globally, but at the same time needs to be workable for businesses. Why CSDDD matters: Legal clarity and alignment: It replaces fragmented national approaches with a single, predictable EU-wide standard. Responsible value chains: It ensures that companies identify and address negative human rights and environmental impacts. Long-term competitiveness: Strong due diligence builds resilience, reduces risk exposure, and responds to investor and market expectations. The focus must remain on revision and simplification of CSDDD and its efficient and sensible implementation."

Theme 2 - Remedy

Ensures companies provide remediation for human rights harms and access to justice for victims.

Theme score

Q2.1 Provide remedy -

Q2.2 Apply leverage -

Q2.3 Grievance mechanism -

Q2.4 Right-holders consultation -

Q2.5 Judicial enforcement with liability -

Q2.6 Remove geographical limitations -

No Evidence

Theme 3 - Supply chain human rights due diligence

Monitors human rights risks across the entire value chain, including suppliers and contractors.

Theme score

Q3.1 Whole value chain coverage -

Q3.2 Risk based approach to actions taken -

Q3.3 HR in contract clauses and supplier CoC -

No Evidence

Theme 4 - Stakeholder engagement

Involves stakeholders in decision-making and human rights risk management processes.

Theme score

Q4.1 Identify stakeholders and their interests -

Q4.2 Engagement channel -

Q4.3 Consult stakeholders on HR risk assessment -

Q4.4 Consult stakeholders on action plans -

Q4.5 Long-term HR risk management -

No Evidence

Positions by legislation

Social LobbyMap analyses the lobbying positions of companies and trade associations across a universe of different legislations on social issues. Detailed scores are calculated as aggregates of all legislations covered for a given entity. To allow for a more nuanced view of the positions entities have taken on the specific legislations, the table below gives an overview of whether the entity has been supportive, mixed/neutral, or unsupportive of a legislation.

Legislation	Position
Omnibus	Not Supporting

Relationship Score

The Relationship Score (expressed as a percentage score from 0 to 100) is an aggregate assessment of how supportive or obstructive the company's industry associations are towards Human Rights policies aligned with the UN Guiding Principles on Business and Human Rights, with 0 being fully opposed and 100 being fully supportive.

Trade Association	Performance band
DIGITALEUROPE	D-
econsense	E-
Eurelectric	E-

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