SAP SE

According to its Annual Report filed with the SEC for fiscal year 2019: "In this context, SAP voluntarily self-disclosed potential export controls and economic sanctions violations to the U.S. DOJ and the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) in September 2017. At the same time, SAP provided notification to the U.S. SEC and responded to an SEC comment letter on export restriction matters in October 2017. SAP has also provided disclosure to the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) based on the same alleged facts. Finally, pursuant to Section 219 of the U.S. Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the U.S. Securities Exchange Act of 1934, SAP has filed the required Iran Notice with the U.S. SEC. The alleged conduct may result in monetary penalties or other sanctions under U.S. sanctions and export control laws."

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According to its Annual Report filed with the SEC for fiscal year 2018: "SAP has taken remedial actions to terminate access to SAP products and services for certain end users and block additional business activities with these end users through SAP or SAP partners. We have implemented further enhancements to our export control compliance program, including new internal controls, and have increased the capacity of the Export Control Compliance team with a particular focus on high-risk countries. SAP has also required additional due diligence, conducted by independent third-parties, for certain SAP partners based in high-risk regions. We are fully committed to compliance with all U.S., EU, and German laws regarding economic sanctions and export controls, including laws restricting the sale, export, and usage of SAP software and services in Iran and in other embargoed countries."

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According to its Annual Report filed with the SEC for fiscal year 2017: "The Company is investigating allegations that certain Company independent partners violated the Company’s contractual terms and sold Company products and services in embargoed countries, including Iran, Syria, Sudan, and Cuba. These third parties presumably did not adhere to the Company’s strict procedures for indirect business activities. To the extent any independent company chooses not to follow the Company’s licensing procedures, the Company is ultimately limited in its ability to stop their activities.  Nonetheless, the Company devotes considerable resources to prevent and mitigate such activities should they occur. We are also investigating allegations regarding direct sales between the Company and certain customers, who may have engaged in unauthorized activities in Iran and other embargoed countries. The Company’s Legal Compliance and Integrity Office is conducting investigations with the assistance of an external law firm."