December 10th marks Human Rights Day around the world and commemorates the anniversary of one of the world’s most groundbreaking global pledges: the Universal Declaration of Human Rights (UDHR). With societal inequality, conflict, political polarization, and intensifying climate change on the rise, it is ever more important that businesses play their role in living up to this pledge. They should not infringe on human rights and respect the dignity and fundamental rights and freedoms of all individuals who are affected by their activities, products, or services.
I talked to Stephanie Raabe, human rights officer at SAP, and asked her three questions about SAP’s progress in embracing this role in the past 12 months.
Q: A year ago, you explained how SAP was working to take its human rights due diligence processes to the next level. The aim was to improve how SAP “knows and shows” 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 human rights due diligence program, 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 – 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’s 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’s Global Anti-Discrimination Policy, mandatory anti-discrimination and anti-harassment training, or SAP’s comprehensive diversity and inclusion programs. The teams involved are doing such a great job that currently no additional measures are required.
Secondly, in SAP’s supply chain, SAP has established contractual assurances through its Supplier Code of Conduct, 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 SAP to handle AI responsibly and avoid negative impacts specifically in the areas of discrimination and privacy. This is why, many years ago, SAP launched its Guiding Principles for AI Ethics and implemented dedicated due diligence governance and processes. In 2024, SAP updated its Global AI Ethics policy to align with UNESCO’s “Recommendation on the Ethics of AI.” We further strengthened SAP’s commitment by establishing an AI ethics office 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 our first human rights report in line with the German Supply Chain Act 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 UN Global Compact, Business for Social Responsibility, and econsense.
Another lesson learned for us was that it can’t 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’s procurement organization onboard, but also all other decision-makers involved with supplier selection.
Christine Susanne Mueller is deputy human rights officer at SAP.
