Anti-Corruption Laws
As an SAP Partner, Eclectic employees must not make, authorize, or offer any bribes, kickbacks, or payments of money or anything of value to anyone for the purpose of obtaining or retaining business or influencing any favorable business decision related to SAP. This applies to:
- Officials, employees, and representatives of any government or public/international organization
- Any other third party — whether in the public or private sector
This includes situations where there is reason to believe that money or value given will be passed on to a government official or a private-sector decision maker.
Public Sector Hospitality — Prohibited
It is prohibited to invite public sector customers to hospitality events. Public sector customers include:
- Government officials
- Public sector employees
- Employees of state-owned enterprises
- Employees of government departments or agencies (military, public schools, scientific research bodies)
- Representatives of political parties
Hospitality events are defined as events whose agenda is not principally business-focused.
Applicable Laws
Partners are required to comply with the German Criminal Code, the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and all applicable local anti-bribery laws.
Offering and Accepting Business Courtesies
Partners must use discretion to ensure that any expenditure — gifts, meals, or entertainment — offered to or received by any SAP employee or third party is in the ordinary and proper course of business and could not reasonably be construed as a bribe or improper inducement.
A Simple Test
Ask yourself: "Would public disclosure of this business courtesy be embarrassing to Eclectic or SAP?" If yes, do not proceed.
When Business Courtesies Are Acceptable
Meals or entertainment are permitted in connection with SAP business only when they:
- Serve a genuine business purpose
- Do not inappropriately influence any business decision
- Are not offered during any pending bidding or negotiation process
- Are given openly and transparently
- Are not unlawful or contrary to ethical business principles
Spending Limit
SAP recommends that meals or business entertainment should not exceed €50 per person. Local rules may require a stricter limit.