The Legal Compliance & Integrity Office (LCIO) is a part of the Global Finance & Administration Board area, and reports to both SAP SE’s Global CFO and the Audit Committee of the Supervisory Board.  Our mission is to advance SAP’s business goals by promoting a culture of integrity, and by mitigating a defined set of legal risks.  The LCIO is responsible for various SAP compliance initiatives, including oversight and support of the SAP Code of Business Conduct, employee compliance training and communications, and the global governance document framework.  We also monitor and enforce compliance.  Our focus includes compliance with the FCPA (Foreign Corrupt Practices Act), UK Bribery Act, and other global anti-corruption and bribery laws, anti-competition compliance (in tandem with field legal), intellectual property compliance and export controls regulations’ support with other key departments.


The successful candidate will be expected to take ownership in managing a dynamic landscape, with support and guidance from North America and Global LCIO Leadership. His/her key responsibilities will be:

  • Provide compliance advice on Compliance matters relating to SAP’s North American entities and ensure compliance principles are adhered to in Management decision-making, so that SAP acts in accordance with best-in-class compliance standards;
  • Develop and administer policies and training on compliance topics including avoidance of bribery and corruption, competition law concerns, misuse of third party intellectual property, handling confidentiality and conflicts of interest, doing business with government customers, fraud in the contracting process, general fraud, etc.
  • Manage investigations as needed and interact with HR and Legal regarding consequence management.
  • Directly support the legal compliance aspects of managing third party relationships
  • Review and analyze donation, sponsorship, membership requests.
  • Review and analyze hospitality and business event invitations and new local events.
  • Review and analyze Due Diligence for Partners
  • Handle translations and localizations of CoBC, trainings and other policies as needed.
  • Conduct trainings.
  • Interact with employees, including senior leaders, to clarify questions regarding SAP Policies.
  • Assist with Compliance Risk Assessments and implementation of mitigation plans.
  • Manage adoption and localization of global projects
  • Monitor changes to legal and regulatory climate/guidelines applicable to the company and proactively develop solutions
  • Effectively channel inquiries and complaints; provide clarification & advice; assist in effective response mechanism. Expert level grasp on complaint reporting mechanisms and how to handle them.
  • Proper administration of SAP Code of Business Conduct and ensuring single point of contact for issues relating to the Code.
  • Assist in operating the Regulatory and Compliance risk assessment module and follow up on risk mitigation processes
  • Monitor compliance trends in North America and globally, including compliance initiatives, industry compliance failures and other internal and external Compliance trends to provide insight for leadership knowledge forums, newsletters and employee groups
  • Track and report compliance issues to LCIO management on a periodic basis


  • Full proficiency with English is required; secondary language skills in French and/or Spanish are nice-to-have
  • Accredited lawyer or other experienced compliance professional is required
  • Minimum 8 years of work experience, especially experience in a legal, compliance, organization governance, risk management and/or audit type role
  • Hands-on with extreme attention to detail and written documentation
  • Ability to do in-depth research and to interpret written guidelines and documents
  • Proactive, dynamic and result driven individual
  • Strong grasp of code of conduct, business ethics policies and current compliance practices
  • Experience handling compliance investigations highly desirable
  • Demonstrated ability to navigate complex issues
  • Demonstrated ability to manage senior leadership in dynamic environments
  • Experience in the areas of detection and prevention of fraud or corruption preferred
  • Demonstrated ability to work with international, virtual teams with sensitivity to cultural differences
  • Project Management experience is highly desirable
  • Very good communication and collaboration skills
  • Comfortable in MS office tools and IT business environment
  • Previous experience in the IT industry is preferable.
  • Experience designing and/or documenting business processes and analyzing related gaps

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