Independent Assurance Report

To the Executive Board and Shareholders of SAP AG

Introduction

We have been engaged by the Executive Board of SAP AG to provide assurance on the ‘SAP Sustainability Report 2010’ (Further referred to as ‘The Report’). The Report, including the identification of stakeholders and material issues, is the responsibility of the company’s management. Our responsibility is to provide assurance on the information contained in The Report.

Scope

Our engagement was designed to provide:

• reasonable assurance on whether the 2010 data for the carbon footprint in The Report are, in all material respects, presented in accordance with the internal reporting criteria;
• limited assurance on whether SAP’s description of their alignment with the AA1000 Accountability Principle Standard (2008) in The Report is, in all material respects, presented in accordance with the criteria set out in AA1000APS (2008);
• limited assurance on whether the other information in The Report is, in all material respects, presented in accordance with the Sustainability Reporting Guidelines (G3) of the Global Reporting Initiative.

The web pages marked ‘Independently Verified by KPMG’ have been part of the scope of our engagement.

The scope of our engagement conforms to the requirements of a Type 2 assurance engagement as set out in the AA1000 Assurance Standard (2008) of AccountAbility. A limited level of assurance under ISAE 3000 is consistent with a moderate level of assurance under AA1000AS.

Procedures performed to obtain a limited level of assurance are aimed at determining the plausibility of information and are less extensive than those for a reasonable level of assurance.

Reporting criteria

SAP AG applies the AA1000APS (2008) criteria for the three principles of inclusivity, materiality and responsiveness as set out on sections GRI 4.14-4.17.

SAP AG applies the Sustainability Reporting Guidelines (G3) of the Global Reporting Initiative for The Report, supported by internally developed guidelines on the carbon footprint, as detailed in the explanatory notes of this Report. We believe that these criteria are suitable in view of the purpose of our assurance engagement.

Standards

We conducted our engagement in accordance with the International Standard for Assurance Engagements (ISAE) 3000: Assurance Engagements other than Audits or Reviews of Historical Financial Information, issued by the International Auditing and Assurance Standards Board and the AccountAbility ‘AA1000 Assurance Standard (2008)’.

The ISAE 3000 Standard requires, amongst others, that the assurance team possesses the specific knowledge, skills and professional competencies needed to understand and review sustainability information, and that they comply with the requirements of the Code of Ethics for Professional Accountants from the International Federation of Accountants to ensure their independence.

Procedures

Our procedures included the following:

• An evaluation of the results of SAP AG’s stakeholder consultation process and processes for determining the material issues for SAP AG’s key stakeholder groups;
• A media analysis and internet search for references to SAP AG in the reporting period;
• Interviews with relevant staff concerning the sustainability strategy, communication and management of these in the business, and for other staff responsible for providing the information in The Report;
• Reviews of the systems and processes for information management, internal control and processing of the qualitative and quantitative information in The Report at corporate level;
• An evaluation of the design, existence, and testing of the operation of the systems and methods used to collect and process the data reported for the carbon footprint, including the aggregation of the data into the information as presented in The Report;
• Auditing the data for the carbon footprint using internal and external documentation, to determine in detail whether the data for the carbon footprint as presented in The Report correspond to the information in the relevant underlying sources and whether all the relevant information contained in such underlying sources has been included in The Report;
• Conducting site visits to Walldorf, St. Leon Rot and London to assess the quality of information management systems and the reliability of the data as reported to corporate level;
• Collecting and reviewing internal and external documentation to determine whether the information in The Report is supported by sufficient evidence;
• Assessing the reasonableness of the assumptions underlying the forward-looking statements set our in The Report;
• An evaluation of whether the information presented in the report is in line with our overall knowledge of, and experience with, sustainability at SAP AG.

Following our review we discussed changes to the draft reports with SAP AG, and reviewed the final version of The Report to ensure that it reflected our findings.

Conclusion

1. In relation to the AA1000APS principles of inclusiveness, materiality and responsiveness:

Based on the procedures performed nothing came to our attention to indicate that SAP AG has not applied, in all materials respects, the AA1000APS (2008) principles as set out on sections GRI 4.14-4.17. As SAP AG has disclosed, the following aspects require further alignment with the criteria in the AA1000APS principles:

• In relation to the principle ‘Inclusiveness’: to further formalize and be transparent on the process of stakeholder identification and prioritization in order to provide a more complete view of stakeholder input.
• In relation to the principle ‘Materiality’: to extend the materiality determination process to all levels of the organization and to further improve documentation around this process.
• In relation to the principle ‘Responsiveness’: to further develop internal capacities to respond to stakeholder demands and to be more transparent about the way stakeholder feedback contributes to decision-making processes.

2. On The Report:

Based on the procedures performed, as described above, we conclude that:

• The 2010 data for the carbon footprint in The Report are, in all material respects, presented in accordance with the internal reporting criteria and
• Nothing came to our attention to indicate that the other information in The Report is not, in all material respects, fairly presented in accordance with the Sustainability Reporting Guidelines (G3) of the Global Reporting Initiative.

Commentary

Without affecting the conclusions presented above, we would like to draw the readers’ attention to the following:

For the carbon footprint SAP has developed internal guidelines for the collection and reporting of data. For other parameters such as waste and water and certain sustainability related topics within procurement, guidelines and related internal controls are not implemented to a similar level. This increases the risk that performance can not be managed and monitored effectively. We therefore recommend SAP to strengthen the guidelines and related controls throughout the organisation for the material parameters and topics.

Amstelveen, 23 March 2011

KPMG Sustainability

W.J. Bartels RA