Key Findings
- Economic: SAP maintains wholly owned Israeli subsidiaries, offices, R&D activity, Tel Aviv cloud infrastructure, and acquired Tel Aviv-headquartered WalkMe for approximately US$1.5 billion in 2024.1, 2, 3
- Military and digital: SAP and its workers’ union reportedly purchased produce donated through NGOs assisting IDF soldiers in 2023. Separately, a 2016 report confirms Navy use of SAP HANA for operational and intelligence integration; it does not establish SAP operation of that system or weapons-effects software.4, 5
- Political: SAP’s reported €250,000 Magen David Adom donation and corporate/union produce purchases benefiting soldiers govern the political score under the rubric’s military-welfare donation rule. Civilian assistance and employee volunteering remain distinct; no recurring military programme is established.4
- Not found: No public evidence identified of SAP facilities or direct operations in settlements or other occupied Palestinian territory, or of SAP appearing in the reviewed OHCHR settlement-business database updates.6, 7, 8
Target Profile
| Field | Detail |
|---|---|
| Company Name | SAP SE |
| Jurisdiction | Federal Republic of Germany.9 |
| Headquarters | Walldorf, Germany.9 |
| Sector | Enterprise software, cloud services, data and business-technology platforms, and R&D.1, 10 |
| Ownership | Publicly traded company; FY2025 filings identify wholly owned Israeli subsidiaries and do not give major shareholders special voting rights.11, 12 |
| Key Executives / Governance | Christian Klein, CEO; Pekka Ala-Pietilä, Chairperson of the Supervisory Board.13 |
| Israeli-Nexus Summary | SAP has a substantial, wholly owned Israeli corporate, R&D, cloud, and public-sector footprint, alongside documented historical defence deployments and dated public-sector procurement records whose later continuation is not assumed.1, 14, 15 |
Key Facts:
- SAP Labs Israel was founded in 1998 and SAP describes it as central to work on Business AI, multi-cloud, user experience, and privacy.10
- SAP’s reported Israeli group entities include SAP Israel Ltd., SAP Labs Israel Ltd., SAP Portals Israel Ltd., Loyalsys Technologies Israel Ltd., and WalkMe Ltd.1
- SAP’s PartnerEdge guide assigns Israel to SAP Israel Ltd. and Palestine to SAP Middle East & North Africa LLC; this is a channel-territory designation, not evidence of settlement activity.16
Executive Summary
SAP’s documented Israel/Palestine nexus is principally an extensive commercial and operational presence in Israel. Its disclosures identify wholly owned Israeli subsidiaries, local offices, an R&D centre, Israel-specific product localisation, and Tel Aviv cloud-service availability. SAP completed its acquisition of Tel Aviv-headquartered WalkMe in September 2024, following an announced transaction value of approximately US$1.5 billion. The record supports a durable economic relationship, but does not publicly quantify SAP’s Israel-specific revenue, repatriated profits, state aid, tax benefits, or sovereign-debt exposure.1, 2, 3, 17
The military score rests on a bounded physical-support episode: in November 2023, SAP and its workers’ union reportedly purchased produce for donation through associations and NGOs assisting evacuees and IDF soldiers. Employees separately delivered meals, clothing and equipment to soldiers and base camps. Corporate purchasing and employee volunteering are distinct acts; the report establishes neither recurring supply nor a paid base-services contract. The civilian beneficiaries are not counted as military recipients.4
The governing digital evidence is a July 2016 report on Israeli Navy use of SAP HANA for real-time integration of operational and intelligence information, including command-and-control, target-handling and sensor-to-shooter information flows. One platform was live; more installations were planned. The Navy IT unit was the integrator. Neither a direct SAP–Navy contract nor SAP operation, autonomous target selection or weapons-effects software is established. The score discounts the bounded historical scope without inventing present continuation or cessation. Current government ERP use remains a separate, lower-scoring administrative relationship.5, 18
The audits also contain significant limiting and exculpatory findings. No public evidence identified of SAP manufacturing weapons, supplying kinetic subsystems, maintaining a settlement facility, operating directly in settlements or other occupied Palestinian territory, or being listed in the reviewed OHCHR settlement-business database documents. A police tender documents SAP workflow supporting a countrywide service contract that included “Judea and Samaria,” but it does not identify a particular West Bank SAP deployment, work order, or direct SAP territorial contract.6, 7, 19
Under the human-vetted V6.5 assessment, SAP receives a BRS of 762, placing it in Tier B (Severe Complicity). The highest domain is political: the rubric expressly treats corporate Magen David Adom donations as military-welfare support, and the record also contains company-attributed produce purchases benefiting soldiers. That classification is a methodological judgement, not an independent legal finding or a claim that all civilian aid supports the military. Current core R&D and the bounded Navy integration evidence contribute separately. The score retains the source limits on settlements, weapons systems and autonomous targeting.4, 10, 5
Timeline of Relevant Events
| Date | Event |
|---|---|
| 1998 | SAP Labs Israel was founded.10 |
| 2000 | SAP acquired OFEK-Tech, one of its recorded Israeli acquisitions.20 |
| 2001 | SAP acquired TopTier; SAP history describes TopTier as Israel’s market leader in enterprise portals.21 |
| 20 May 2004 | Globes reported an IDF ERP commission covering inventories, personnel, procurement, storage, production, and budgets at logistics centres.22 |
| 19 December 2006 | Globes reported that the IDF suspended an organisation-wide ERP consolidation project while units still needed links to the Ministry of Defense SAP-based ERP system.23 |
| January 2012 | Reporting stated that SAP Israel agreed to provide ERP and business-intelligence products to IDF branches and Ministry of Defense units under a reported US$10 million, three-year arrangement.14 |
| December 2012 | Calcalist reported SAP HANA deployment at IDF Meitav recruitment and classification bases for personnel-assignment reporting.24 |
| 28 June 2015 | Calcalist reported an approximately US$22 million, five-year SAP ERP and business-intelligence licensing agreement for Ministry of Defense and IDF units.25 |
| April 2016 | Reporting described a Ministry of Defense SAP SRM procurement platform serving units including the Air Force, Navy, Military Intelligence, and other Ministry functions.26 |
| July 2016 | Reporting confirmed one live Navy HANA platform and further planned installations for real-time operational and intelligence integration.5 |
| October–November 2023 | SAP’s CEO posted support for colleagues and families in Israel; Globes reported employee grants and donations and assistance benefiting evacuees and IDF soldiers.27, 4 |
| 5 June 2024 | SAP announced its agreement to acquire WalkMe for approximately US$1.5 billion.3 |
| 12 September 2024 | SAP announced completion of its WalkMe acquisition.3 |
| 24 November 2024 | Israel Government Procurement published a proposed SAP Israel police-system expansion extending to September 2031.28 |
| 25 March 2025 | Accountant General Protocol 5047 approved police SAP expenditure through August 2026 and recorded a conditional option through September 2031.15 |
| 2025 | Ministry of Defense material credited an outgoing digital director with leading establishment and implementation of the Ministry’s SAP system.29 |
| 2026 | SAP hosted an Israeli spend-management event with an Elbit Systems customer presentation on vendor management; the disclosed material did not identify product scope or a weapons-programme connection.30 |
Corporate Overview
SAP SE is a German public company headquartered in Walldorf. Its reviewed filings portray a conventional publicly traded enterprise, not an Israeli state-owned or state-directed company. The filings identify no Israeli government ownership, golden share, board-appointment right, or charter mechanism linking SAP’s primary mission to an Israeli state geopolitical project.9, 11
SAP’s Israeli footprint is direct rather than solely distributor-based. Its filings identify wholly owned entities including SAP Israel Ltd., SAP Labs Israel Ltd., SAP Portals Israel Ltd., Loyalsys Technologies Israel Ltd., and WalkMe Ltd. SAP lists SAP Israel Ltd. in Ra’anana, and its visitor-identity materials identify SAP Labs and SAP Portals facilities in Ra’anana, with an SAP Labs facility in Tel Aviv. SAP’s current materials describe the Israel lab as a significant R&D site, and industry-association material reports approximately 1,000 SAP Labs Israel employees; that employment figure is an attributed association statement rather than a government designation.1, 2, 10, 31, 32, 12
The relationship also includes acquisitions and infrastructure. SAP’s history records acquisitions of OFEK-Tech, TopTier, and TopManage; acquired-brand materials identify Gigya as another Israeli-linked acquisition. WalkMe, whose pre-close filing described headquarters in Tel Aviv, became a wholly owned SAP subsidiary in 2024. SAP’s cloud documentation lists Tel Aviv as an available location for multiple cloud-service families. These facts establish continuing investment, local employment, software development, and cloud infrastructure; they do not establish settlement operations or a distinct Israeli military sovereign-cloud offering.3, 10, 33, 21, 20, 34
SAP’s relationship with Israeli state customers includes government-sector marketing, the SAP-based Sigma/Merkava government ERP environment, and public procurement records. The public evidence separately documents defence, police, prison-service, and health-sector SAP use. Not every public-sector relationship is a defence relationship, and the reviewed records do not establish current status for every historical contract. The police option after 31 August 2026 is conditional; its exercise is not verified merely because that date has passed.14, 15, 18
Domain Summaries
Military: Military
Mechanism of Involvement
The company-attributed physical-support finding is SAP and its workers’ union purchasing agricultural produce for donation through NGOs assisting IDF soldiers in November 2023. Employees also volunteered to deliver meals, clothing and equipment to soldiers and base camps. The corporate purchase governs Military: I=3.2 reflects non-lethal logistical sustainment; M=2.8 reflects the single documented episode; P=6 reflects delivery mediated by associations and NGOs. Employee deliveries are not automatically treated as corporate-directed operations. The resulting military score is 1.10. Civilian evacuee assistance is outside this military result.4
The following software relationships provide military-customer context and are assessed as digital enablement, rather than physical supply.
Public reporting documents SAP ERP use by the IDF’s Technological and Logistics Directorate from 2004, including inventory, personnel, procurement, storage, production, and budget functions. Subsequent reporting documented Ministry of Defense and IDF SAP frameworks and licence arrangements across the Technology and Logistics Directorate, Human Resources Directorate, Ground Forces, Planning Directorate, Navy, Home Front Command, and other units.22, 25, 35
The record includes SAP-based recruitment, personnel, purchasing, transportation-administration, logistics, shipping, and business-intelligence functions. The Ministry of Defense SAP SRM procurement system was reported to support purchasing workflows from supply orders through invoices. A Ministry budget proposal states that an IDF and defence-establishment international-shipment management system would be replaced with a SAP-based system. This supports an administrative and combat-support logistics nexus, not evidence that SAP itself moved cargo, ran warehouses, operated bases, or provided freight, catering, or facilities services.26, 19, 36
The closest reviewed operational software nexus is the 2016 Navy HANA report, assessed under Digital below. It describes operational and intelligence integration, with one platform live and others planned, and identifies the Navy IT unit as integrator. It does not establish that SAP designed target-selection algorithms, operated the Navy system or produced weapons effects.5
SAP also markets defence-and-security and aerospace-and-defence functionality with operational planning, force movement, logistics, readiness, maintenance, and analytics features. Its materials do not describe autonomous target selection, guidance, fire control, or automated weapons effects.37
Counter-Arguments and Evidence Limits
SAP’s strongest defence is that the documented products are predominantly enterprise-management, administrative, personnel, procurement, and logistics tools of a civilian software company. No public evidence identified that SAP manufactures weapons or supplies physical military components, ruggedised hardware, battlefield sensors, kinetic-targeting software, guidance electronics, or critical subsystems for Israeli weapons platforms.37
The evidence concerning IAI, Elbit, and the Navy is limited. The IAI record concerns enterprise software through an integrator and financial-control functionality, not a verified direct SAP weapons contract.38, 39 The 2026 Elbit association concerns a vendor-management presentation; it does not disclose the product, contract, datasets, business units, programme, or link to weapons production. Elbit separately stated in 2017 that it selected Infor, rather than SAP, for its company-wide OneERP platform.30, 40
No public evidence identified of SAP as a named company entry in the reviewed SIBAT directories, Israel-specific export-licence decisions, military end-user certificates, sanctions enforcement, or a SAP-specific public termination of Israeli defence contracts. The police tender’s inclusion of “Judea and Samaria” establishes an SAP-generated administrative workflow for a territorially broad maintenance tender, not a named West Bank facility or direct SAP contract in occupied territory.19, 41
Named Entities and Evidence Map
- SAP / workers’ union / military beneficiaries: Reported corporate produce purchases through NGOs and separately reported employee deliveries; a bounded 2023 physical-support episode.4
- IDF / Ministry of Defense: Documented SAP ERP, BI, recruitment, procurement, logistics, and shipping administration.22, 26, 25, 36
- Israeli Navy: Reported SAP HANA infrastructure serving logistics and operational information flows; no verified weapons-effects function.5
- Israel Police / Israel Prison Service: SAP administrative, payroll, data-warehouse, and maintenance-related procurement records; these are security-body relationships, not proof of military weapons support.15, 42
- IAI / Elbit Systems: Limited records of enterprise-finance or vendor-management association; no verified SAP supply of physical components, weapon subsystems, joint weapons development, or co-production.30, 40
Digital: Digital
Mechanism of Involvement
The governing frame is the historically confirmed Navy HANA deployment. The July 2016 source describes real-time integration across operational and intelligence information flows, including command-and-control, target handling and sensor-to-shooter processes. This supports intelligence integration at I=7.4, without establishing a targeting algorithm or weapon effect. One platform had gone live and more installations were planned, supporting bounded M=5.5. The Navy IT unit integrated the platform; absent evidence of a direct SAP–Navy contract, SAP deployment or SAP operation, P=6 describes an indirect but meaningful provider relationship. The resulting V=4.98 exceeds the current government ERP frame’s V=4.80. No present continuation or verified cessation of the exact Navy implementation is inferred.5, 18
SAP’s Israel footprint includes SAP Labs Israel’s work on Business AI, multi-cloud, user experience, privacy, SAP BTP, SAP Business Data Cloud, SAP Build, and SAP Customer Data Platform. SAP’s cloud documentation also lists a Google Cloud-backed SAP Business Technology Platform region in Tel Aviv and Tel Aviv data-centre availability for SAP cloud-service families.10, 33, 43
SAP completed the WalkMe acquisition in 2024. SAP stated that WalkMe’s digital-adoption platform, which integrates generative AI, would enrich SAP Business AI offerings. WalkMe’s filing described it as an Israeli company headquartered in Tel Aviv and noted that it was subject to Israeli laws concerning governmental access to data.3, 44
Israeli government sources describe Sigma/Merkava as a SAP-based core-government ERP environment across roughly 90 ministries and units, supporting functions such as HR, procurement, finance, and budgeting. A 2025 Ministry of Health procurement notice records SAP licence and maintenance procurement through SAP Israel Ltd. This documents continuing public-administration activity, though the cited notice is not a defence procurement record.18, 45
Counter-Arguments and Evidence Limits
No public evidence identified in the reviewed material that SAP developed, sold, licensed, or maintained offensive cyber tools, zero-day exploit tools, digital weapons systems, autonomous target-generation systems, automated lethality tools, or autonomous tracking systems for Israeli state actors.46
No public evidence identified that SAP used Israeli-origin facial recognition, gait analysis, behavioural analytics, predictive policing, social-media monitoring, workforce surveillance, or related technologies in its cloud stack. The SAP Israel visitor identity-management statement evidences identity and visitor processing at premises, but the audit did not connect it to biometric or surveillance-vendor deployments.32
Project Nimbus materials identify AWS and Google Cloud, not SAP, as the selected public-cloud providers. Although the framework allows ministries to procure third-party services through marketplaces, no SAP-specific Nimbus award or named SAP implementation role was identified. General Tel Aviv cloud availability is therefore not proof of a military sovereign-cloud arrangement.33, 47
The data-exposure rule does not require a state contract. However, cloud-region availability and WalkMe’s general legal-access disclosure do not identify a qualifying sensitive SAP data pool actually stored, routed, processed or exposed in Israel. This record therefore does not support a higher data-exposure frame.33, 44, 43
Named Entities and Evidence Map
- Israeli Navy: Historically confirmed HANA intelligence integration; bounded rollout and provider-attribution limits govern the digital score.5
- SAP Labs Israel: R&D in business AI, cloud, user experience, and privacy.10
- WalkMe Ltd.: Israeli-headquartered acquired subsidiary; reviewed evidence does not identify supply to Israeli military or security bodies.3, 44
- Sigma/Merkava / Ministry of Health: SAP-based government ERP and a documented 2025 health-sector procurement notice.18, 45
- Project Nimbus: AWS and Google Cloud are the named public-cloud providers; no SAP-specific award identified in the reviewed record.47
Economic: Economic
Mechanism of Involvement
Core R&D governs the economic score. SAP Labs Israel has operated since 1998; SAP identifies central Business AI and core-product work, while IATI reports approximately 1,000 staff across Ra’anana and Tel Aviv. This supports I=7.2/M=7.2/P=9.1 and V=7.20: substantial sustained R&D directly operated within the group. The completed WalkMe acquisition independently supports a strategic-investment frame at V=6.50, below core R&D. German parent identity is preserved; subsidiary ownership does not make SAP an Israeli-origin company.10, 31, 12, 3
SAP’s high economic-nexus evidence rests on its wholly owned Israeli subsidiaries, longstanding R&D operations, local offices, cloud infrastructure, acquisitions, investment exposure, local billing infrastructure, and ongoing Israel-market events. Its 2024 and 2025 filings list SAP Israel, SAP Labs Israel, SAP Portals Israel, Loyalsys Technologies Israel, and WalkMe as 100%-owned subsidiaries.1, 12
The WalkMe acquisition provides a particularly clear capital-investment example: SAP announced an approximately US$1.5 billion acquisition agreement in June 2024 and completed the transaction in September. WalkMe disclosed that it was organised under Israeli law, registered with the Israeli Registrar of Companies, headquartered in Tel Aviv, and employed approximately 1,000 people as of December 2023.3, 48
SAP’s historical Israeli investment includes OFEK-Tech, TopTier, TopManage, and Gigya. Its 2024 filing also identifies Israeli-linked “Other Equity Investments,” including Data.R.X./Datricks, BioCatch, and 83North IV. SAP’s public reporting places those exposures within a much larger global investment and venture portfolio; it does not separately quantify their value or returns.1, 21
SAP’s product material shows Israel-specific legal, tax, and e-invoicing functions, including electronic-invoice submission to Israeli tax authorities. These materials support market adaptation and commercial activity in Israel, rather than consumer-goods sourcing or settlement-origin merchandise trade.17
Counter-Arguments and Evidence Limits
The 2023 charitable produce purchase is documented; it does not establish a recurring agricultural supply chain. No reviewed evidence establishes recurring agricultural sourcing, a consumer-goods import business, SAP retail channels for Israeli or occupied-territory goods, settlement-origin sales, or origin-labelling disputes. The ordinary business footprint remains software, cloud, offices, R&D and acquisitions.4, 1, 17
No public evidence identified of direct SAP operations inside West Bank settlements, East Jerusalem settlements, or the Golan Heights. The document-scoped reviews did not identify SAP in the reviewed OHCHR settlement-business database updates or UN document A/HRC/59/23; those findings are limited to the reviewed documents and are not broader exoneration.6, 7
SAP does not publicly report Israel-specific revenue, dividends, remittances, or profit transfers. No public evidence identified of Israeli sovereign-bond holdings, underwriting Israel Bonds, Preferred Technology Enterprise status, Israel Innovation Authority grants, formal Israeli state aid, or formal designation as Israeli critical national infrastructure.1, 11
Named Entities and Evidence Map
- SAP Israel Ltd., SAP Labs Israel Ltd., SAP Portals Israel Ltd., Loyalsys Technologies Israel Ltd., WalkMe Ltd.: Listed wholly owned Israeli subsidiaries.1
- SAP Labs Israel: Local R&D operation; industry-association material reports approximately 1,000 employees.10, 31
- WalkMe: Tel Aviv-headquartered acquired company; approximately US$1.5 billion transaction announced in 2024.3, 48
- Tel Aviv cloud infrastructure: Public cloud-service documentation identifies Tel Aviv locations; no separate Israeli military sovereign-cloud offering was identified.33
Political: Political
Mechanism of Involvement
The governing political acts are SAP’s reported €250,000 donation to Magen David Adom and the SAP/union purchase of produce through NGOs assisting IDF soldiers in November 2023. The report also describes civilian and employee relief, which must remain distinct. Under Principle 5 of the applied rubric, qualifying corporate military-welfare donations - including Magen David Adom by express rule - receive Impact 8.9 at the top of Band 8. Magnitude 6.5 reflects a national channel documented during a brief 2023 episode; Proximity 9 reflects SAP’s own donation and purchasing decisions. The resulting political score is 8.26. This is a rubric classification, not an independent legal finding about MDA or a claim of recurring SAP military financing.4
The audit records a routine commercial, government-sector, and operational posture toward Israel. SAP markets to government customers in Israel, maintains Israeli offices and entities, and published a customer reference concerning Ministry of Health production-readiness support. Its 2023 Integrated Report treated the “Israel-Hamas conflict” as a geopolitical-risk example rather than as a distinct human-rights or public-policy commitment topic.49, 50, 51
After 7 October 2023, CEO Christian Klein posted that SAP was committed to supporting colleagues and their families in Israel. SAP was also reported among German companies signing the “Never again is now” advertisement, whose reported text condemned Hamas’s attack and referred to civilians in Israel and Gaza. The reviewed 2024 CEO-letter and report materials did not identify an additional Israel-specific SAP corporate statement beyond the documented 2023 material.27, 52
SAP has regulated lobbying structures: it reports registrations in German, selected state, EU, and US lobbying systems; FEC data list SAP America Inc PAC as an active corporation/lobbyist PAC; and US records list SAP America as a lobbying registrant. These facts establish general public-policy participation, not Israel-specific advocacy.50, 53, 54
Counter-Arguments and Evidence Limits
The reviewed filings and registry records do not identify Israel-specific or anti-BDS lobbying, or SAP PAC activity tied to Israel/Palestine legislation. The donation report does not name Friends of the IDF, a reservist fund, a defence manufacturer or a particular unit. These limits do not negate the affirmative MDA donation or produce support for soldiers. No reviewed evidence identifies SAP donations to JNF/KKL or settlement organisations.50, 53, 54, 4
No public evidence identified that SAP has a state ownership stake, golden share, state board-appointment right, military-heritage brand identity, or primary corporate mission tied to advancing an Israeli state geopolitical project. Its governance materials instead depict a conventional publicly traded corporation.11, 13
No public evidence identified of SAP HR sanctions against pro-Palestinian staff, litigation against unions over pro-Palestine speech, suppression of shareholder resolutions on Israel/Palestine due diligence, or an Israel/Palestine-specific moderation pattern in the reviewed DSA reporting. A reported 2023 internal controversy did not establish a formal SAP disciplinary outcome.55, 56
Named Entities and Evidence Map
- SAP / Magen David Adom / corporate-and-union produce support: Documented corporate acts governing the political donation frame; civilian relief and employee deliveries remain distinct.4
- “Never again is now” advertisement: A researched public statement; the reported text concerns the attack and civilians in Israel and Gaza. It does not establish a formal state partnership and ranks below the supported donation frame.52
- Christian Klein: Public post after 7 October 2023 supporting SAP colleagues and families in Israel.27
- SAP Israel / Ministry of Health: Government-sector marketing and documented support reference.49, 51
- SAP America Inc PAC / SAP America: General US PAC and lobbying registrations; no Israel-specific activity identified in the reviewed materials.53, 54
- Pekka Ala-Pietilä: Current Supervisory Board Chair; no reviewed material identified personal affiliations with the specified pro-Israel or anti-BDS groups.13
BDS-1000 Score
Method: V6.5.
| Domain | I | M | P | V-Domain Score |
|---|---|---|---|---|
| Military | 3.20 | 2.80 | 6.00 | 1.10 |
| Digital | 7.40 | 5.50 | 6.00 | 4.98 |
| Economic | 7.20 | 7.20 | 9.10 | 7.20 |
| Political | 8.90 | 6.50 | 9.00 | 8.26 |
- V_MAX: 8.26 Avg_OTHERS: 4.43
- BRS Score: 762 Tier: B (Severe Complicity)
Political supplies the V_MAX of 8.26 through the rubric’s direct-financing treatment of the documented 2023 corporate donations. Economic reflects current directly operated core R&D; Digital reflects bounded historical Navy intelligence integration; Military reflects company-attributed physical produce support through NGOs. Each domain assesses its distinct effect and attribution. The scores do not establish legal liability and do not infer weapons supply, a current Navy contract or recurring military support from the evidence.4, 10, 31, 5
Methodology Note
- Evidence is limited to the four supplied domain audits and their cited source record.
- Impact (I) assesses documented activity type; Magnitude (M) assesses documented scale; Proximity (P) assesses directness of the nexus.
- The assessment is scale-free: it does not infer culpability from company size, reputation, or allegations unsupported by the audit record.
- Divested, exited, or otherwise discontinued operations are mitigated rather than treated as continuing activity; no such mitigation changes the fixed scores supplied here.
- Entity attribution is specific: a customer, integrator, subsidiary, event participant, or general platform use does not establish transitive responsibility for another entity’s conduct.
- Settlement-related activity may affect both Economic and Political where the evidence supports both vectors. “No public evidence identified” is used where the audits’ checks found no evidence, and document-scoped no-hit findings are not treated as universal exoneration.
Footnotes
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https://www.sap.com/docs/download/investors/2024/sap-2024-annual-report-form-20f.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11
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https://www.sap.com/uk/about/company/office-locations/israel.html ↩ ↩2 ↩3
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https://news.sap.com/2024/09/sap-completes-walkme-acquisition/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10
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https://en.globes.co.il/en/article-sap-provides-war-grants-to-israeli-employees-in-combat-zones-1001461536 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12
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https://www.ohchr.org/sites/default/files/documents/hrbodies/hrcouncil/sessions-regular/session31/database-hrc3136/23-06-30-Update-israeli-settlement-opt-database-hrc3136.pdf ↩ ↩2 ↩3
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https://www.un.org/sexualviolenceinconflict/wp-content/uploads/2025/07/HRC-59-23.pdf ↩ ↩2 ↩3
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https://www.ohchr.org/en/press-releases/2025/09/un-human-rights-office-updates-database-businesses-involved-israeli ↩
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https://www.sec.gov/Archives/edgar/data/1000184/000110465926020058/sap-20251231x20f.htm ↩ ↩2 ↩3
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https://www.sap.com/about/company/innovation/labs.html ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11
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https://www.sec.gov/Archives/edgar/data/1000184/000110465926020058/sap-20251231x20f.htm ↩ ↩2 ↩3 ↩4
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https://www.sec.gov/Archives/edgar/data/1000184/000110465926020058/R214.htm ↩ ↩2 ↩3 ↩4
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https://www.sap.com/sweden/about/legal/impressum-se.html ↩ ↩2 ↩3
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https://www.ynetnews.com/articles/0,7340,L-4176779,00.html ↩ ↩2 ↩3
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https://mr.gov.il/ilgstorefront/en/p/attachment/005056BFAF4C1FE08AF9B99EF95F92E9/%D7%A4%D7%A8%D7%95%D7%98%D7%95%D7%A7%D7%95%D7%9C%20%D7%9C%D7%A4%D7%A8%D7%A1%D7%95%D7%9D ↩ ↩2 ↩3 ↩4
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https://assets.cdn.sap.com/agreements/leveled-partner-agreements/CTSSR/sap-partneredge-contractual-territory-guide-english-v2-2024.pdf ↩
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https://help.sap.com/docs/SAP_S4HANA_CLOUD/4977e7737cc747edb51d806619e3d146/8c9d527ea4c94dd991515f11be735304.html?locale=en-US ↩ ↩2 ↩3
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https://govextra.gov.il/sigma/merkava/home/core-system-implementation/ ↩ ↩2 ↩3 ↩4 ↩5
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https://mr.gov.il/ilgstorefront/en/p/attachment/005056BF4F1A1FE092D3770C9BC792E9/%D7%97%D7%95%D7%91%D7%A8%D7%AA%20%D7%94%D7%9E%D7%9B%D7%A8%D7%96 ↩ ↩2 ↩3
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https://www.sap.com/investors/en/resources/acquisitions.html ↩ ↩2
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https://www.sap.com/about/company/history/2001-2010.html ↩ ↩2 ↩3
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https://www.calcalist.co.il/internet/articles/0,7340,L-3590983,00.html ↩
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https://www.calcalist.co.il/local/articles/0,7340,L-3662976,00.html ↩ ↩2 ↩3
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https://www.linkedin.com/posts/christian-klein_we-are-greatly-saddened-by-the-tragic-loss-activity-7117118403462483968-uaSO ↩ ↩2 ↩3
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https://mod.gov.il/%D7%9B%D7%AA%D7%91%D7%95%D7%AA-%D7%95%D7%9E%D7%91%D7%96%D7%A7%D7%99%D7%9D/%D7%97%D7%93%D7%A9%D7%95%D7%AA-%D7%9E%D7%A9%D7%A8%D7%93-%D7%94%D7%91%D7%99%D7%98%D7%97%D7%95%D7%9F/%D7%A1%D7%9E%D7%A0%D7%9B-%D7%9C-%D7%95%D7%A8%D7%90%D7%A9-%D7%90%D7%92%D7%A3-%D7%93%D7%99%D7%92%D7%99%D7%98%D7%9C-%D7%95%D7%98%D7%9B%D7%A0%D7%95%D7%9C%D7%95%D7%92%D7%99%D7%95%D7%AA-%D7%9E%D7%99%D7%93%D7%A2-%D7%97%D7%93%D7%A9-%D7%9C%D7%9E%D7%A9%D7%A8%D7%93-%D7%94%D7%91%D7%99%D7%98%D7%97%D7%95%D7%9F ↩
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https://events.sap.com/il-sap-connect-day-for-spend-management-il/en_us/home.html ↩ ↩2 ↩3
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https://iati.co.il/wp-content/uploads/2025/01/Booklet-2025.pdf ↩ ↩2 ↩3 ↩4
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https://www.sap.com/mena/about/legal/privacy/visitor-identity-management/israel.html ↩ ↩2
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https://www.sap.com/docs/download/agreements/product-use-and-support-terms/cls/en/list-of-data-centers-for-sap-cloud-services-english-v.1-2025.pdf ↩ ↩2 ↩3 ↩4 ↩5
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https://www.sap.com/israel/products/acquired-brands/what-is-gigya.html ↩
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https://mod.gov.il/media/hnyjk5ta/%D7%94%D7%A6%D7%A2%D7%AA-%D7%AA%D7%A7%D7%A6%D7%99%D7%91-2023-2024.pdf ↩ ↩2
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https://www.sap.com/israel/industries/defense-security.html ↩ ↩2
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https://www.elbitsystems.com/news/elbit-systems-implements-infors-erp-technology-platform ↩ ↩2
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https://mr.gov.il/ilgstorefront/he/p/attachment/005056BF65EB1EDFB186BC0A3243414C/%D7%A4%D7%A8%D7%95%D7%98%D7%95%D7%A7%D7%95%D7%9C%20%D7%9C%D7%A4%D7%A8%D7%A1%D7%95%D7%9D ↩
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https://help.sap.com/doc/bd6250c40c9c4c5391e3009a6f26dc3b/Cloud/en-US/SAP_Cloud_Platform.pdf ↩ ↩2
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https://www.sec.gov/Archives/edgar/data/1847584/000117891324000974/zk2431111.htm ↩ ↩2 ↩3
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https://mod.gov.il/en/departments/applications-and-technology-department ↩
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https://www.sec.gov/Archives/edgar/data/1847584/000117891324000974/zk2431111.htm ↩ ↩2
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https://assets.ctfassets.net/z2fsfx60w22m/1BZJuso0mjt0V7vHfB5Niv/cb09d507b131a4057e688e67a01f21d9/SAP_Integrated_Report_2023.pdf ↩ ↩2 ↩3
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https://www.sap.com/documents/2024/08/28ace105-cf7e-0010-bca6-c68f7e60039b.html ↩ ↩2
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https://www.timesofisrael.com/never-again-is-now-german-companies-condemn-hamas-terror-stand-with-israel/ ↩ ↩2
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https://lobbyingdisclosure.house.gov/lookup.asp?alpha=83 ↩ ↩2 ↩3
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https://pages.community.sap.com/resources-legal/dsa-transparency-report-2024 ↩




















