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SAP SE 2023-2024 Proxy Voting Records

Compiled from SEC Form N-PX filings. Page generated 02 October 2026.

57Reported items
513Asset managers
9,026Fund votes
2024-05-15Meeting date

Proxy season: 2023-2024 2024-2025 2025-2026

Explore SAP SE in the interactive database Compare manager voting policies

How asset managers voted at the SAP SE 2023-2024 meeting

Each item below shows how the 513 asset managers that disclosed a SAP SE vote in their SEC Form N-PX filings actually voted. Share totals are the shares those managers' funds voted, summed across every fund they report. These are reported items, not a count of the ballot: fund filings describe one ballot item in different words. Two descriptions are shown as one item only on evidence — the same text (or one cut short of the other), the same director nominee, or a match to the same row of SAP SE’s own Form 8-K tally — never because they merely read alike. A description that could not be joined that way is listed on its own, so one ballot item can appear more than once.

1. Resolution on the approval of the compensation report for fiscal year 2023

SECTION 14A SAY-ON-PAY VOTES

Combines 7 wordings of this item as funds reported it.

99.6% fund support · no official result

FOR 99%

The 287 asset managers below cast 99.6% of the shares they voted on this item FOR (15,582,131 for, 58,616 against).

FOR: 15,582,131 (98.6%)AGAINST: 58,616 (0.4%)ABSTAIN: 11,225 (0.1%)NOT VOTED: 139,119 (0.9%)WITHHOLD/ABSTAIN: 4,800 (0.0%)UNKNOWN: 3,306 (0.0%)

Largest asset managers voting on “Resolution on the approval of the compensation report for fiscal year 2023” at SAP SE, 2023-2024
Asset manager	For	Against	Vote
HARDING LOEVNER LP	4,249,092	0	For
EAGLE CAPITAL MANAGEMENT LLC	3,091,574	0	For
HARDING LOEVNER FUNDS INC	1,695,271	0	For
Fiera Capital Corp	1,358,943	0	For
Northern Trust	1,140,528	0	For
ENVESTNET ASSET MANAGEMENT INC	852,854	1,399	For
RAYMOND JAMES & ASSOCIATES	565,527	0	For
Natixis	309,509	0	For
MAR VISTA INVESTMENT PARTNERS LLC	284,353	0	For
2023 ETF Series Trust	268,779	0	For
Cardinal Capital Management, Inc.	150,365	0	For
SCOTIA CAPITAL INC.	138,122	0	For
PNC BANK, NATIONAL ASSOCIATION	137,867	0	For
JARISLOWSKY, FRASER Ltd	130,639	0	For
US BANK NATIONAL ASSOCIATION	124,114	0	For
OPPENHEIMER ASSET MANAGEMENT INC.	91,848	0	For
BUFFALO FUNDS	87,391	0	For
TRUIST FINANCIAL CORP	64,948	0	For
LPL Financial LLC	62,027	0	For
DIVIDEND ASSETS CAPITAL, LLC	51,792	0	For
One Capital Management, LLC	0	0	Not Voted
Dash Acquisitions Inc.	0	0	Not Voted
MARSICO INVESTMENT FUND	46,294	0	For
Night Owl Capital Management, LLC	41,598	0	For
HIGHLAND CAPITAL MANAGEMENT, LLC	40,364	0	For

Showing the 25 largest of 287 asset managers. See all 287 in the interactive database.

2. Approve Remuneration Report

COMPENSATION

99.2% fund support · no official result

FOR 99.2%

The 126 asset managers below cast 99.2% of the shares they voted on this item FOR (173,492,071 for, 1,245,276 against).

FOR: 173,492,071 (99.3%)AGAINST: 1,245,276 (0.7%)

Largest asset managers voting on “Approve Remuneration Report” at SAP SE, 2023-2024
Asset manager	For	Against	Vote
Capital Group	34,275,086	0	For
Vanguard	31,767,059	0	For
Fidelity	20,018,291	0	For
BlackRock	18,777,472	0	For
MFS	9,561,938	0	For
Goldman Sachs	6,316,766	0	For
Six Circles Trust	4,919,138	0	For
T. Rowe Price	4,086,804	0	For
JPMorgan	4,044,480	0	For
TIAA	3,075,482	0	For
State Street	2,542,761	0	For
APG Asset Management US Inc.	2,439,004	0	For
Invesco	2,297,123	0	For
Legg Mason	1,859,609	0	For
Desjardins Global Asset Management Inc.	1,740,556	0	For
GMO	1,694,246	0	For
Walter Scott & Partners Ltd	1,622,450	0	For
Brighthouse	1,614,259	0	For
Morgan Stanley	1,352,913	0	For
INVESTMENT CO OF AMERICA	1,214,318	0	For
Columbia Threadneedle	0	1,197,863	Against
Equitable	1,186,576	0	For
AMCAP FUND	1,102,126	0	For
CAUSEWAY CAPITAL MANAGEMENT TRUST	1,032,543	0	For
HARRIS ASSOCIATES INVESTMENT TRUST	795,800	0	For

Showing the 25 largest of 126 asset managers. See all 126 in the interactive database.

3. Approve Remuneration Policy for the Supervisory Board

COMPENSATION

99.9% fund support · no official result

FOR 99.9%

The 118 asset managers below cast 99.9% of the shares they voted on this item FOR (164,395,161 for, 42,013 against).

FOR: 164,395,161 (100.0%)AGAINST: 42,013 (0.0%)

Largest asset managers voting on “Approve Remuneration Policy for the Supervisory Board” at SAP SE, 2023-2024
Asset manager	For	Vote
Capital Group	34,275,086	For
Vanguard	31,767,059	For
Fidelity	20,018,291	For
BlackRock	18,777,472	For
MFS	9,561,938	For
Goldman Sachs	6,316,766	For
Six Circles Trust	4,919,138	For
T. Rowe Price	4,086,804	For
TIAA	3,075,482	For
State Street	2,542,761	For
Invesco	2,297,123	For
Legg Mason	1,859,609	For
GMO	1,694,246	For
Brighthouse	1,614,259	For
Morgan Stanley	1,352,913	For
INVESTMENT CO OF AMERICA	1,214,318	For
Columbia Threadneedle	1,197,863	For
Equitable	1,186,576	For
AMCAP FUND	1,102,126	For
CAUSEWAY CAPITAL MANAGEMENT TRUST	1,032,543	For
HARRIS ASSOCIATES INVESTMENT TRUST	795,800	For
BNY Mellon	746,429	For
Lincoln Financial	683,174	For
American Century	637,210	For
NEW ECONOMY FUND	624,839	For

Showing the 25 largest of 118 asset managers. See all 118 in the interactive database.

4. Amend Articles Re: Proof of Entitlement

CORPORATE GOVERNANCE

100% fund support · no official result

FOR 100%

The 116 asset managers below cast 100% of the shares they voted on this item FOR (164,434,964 for, 0 against).

FOR: 164,434,964 (100.0%)

Largest asset managers voting on “Amend Articles Re: Proof of Entitlement” at SAP SE, 2023-2024
Asset manager	For	Vote
Capital Group	34,275,086	For
Vanguard	31,767,059	For
Fidelity	20,018,291	For
BlackRock	18,777,472	For
MFS	9,561,938	For
Goldman Sachs	6,316,766	For
Six Circles Trust	4,919,138	For
T. Rowe Price	4,086,804	For
TIAA	3,075,482	For
State Street	2,542,761	For
Invesco	2,297,123	For
Legg Mason	1,859,609	For
GMO	1,694,246	For
Brighthouse	1,614,259	For
Morgan Stanley	1,352,913	For
INVESTMENT CO OF AMERICA	1,214,318	For
Columbia Threadneedle	1,197,863	For
Equitable	1,186,576	For
AMCAP FUND	1,102,126	For
CAUSEWAY CAPITAL MANAGEMENT TRUST	1,032,543	For
HARRIS ASSOCIATES INVESTMENT TRUST	795,800	For
BNY Mellon	746,429	For
Lincoln Financial	683,174	For
American Century	637,210	For
NEW ECONOMY FUND	624,839	For

Showing the 25 largest of 116 asset managers. See all 116 in the interactive database.

5. Approve Allocation of Income and Dividends of EUR 2.20 per Share

CAPITAL STRUCTURE

100% fund support · no official result

FOR 100%

The 116 asset managers below cast 100% of the shares they voted on this item FOR (164,434,964 for, 0 against).

FOR: 164,434,964 (100.0%)

Largest asset managers voting on “Approve Allocation of Income and Dividends of EUR 2.20 per Share” at SAP SE, 2023-2024
Asset manager	For	Vote
Capital Group	34,275,086	For
Vanguard	31,767,059	For
Fidelity	20,018,291	For
BlackRock	18,777,472	For
MFS	9,561,938	For
Goldman Sachs	6,316,766	For
Six Circles Trust	4,919,138	For
T. Rowe Price	4,086,804	For
TIAA	3,075,482	For
State Street	2,542,761	For
Invesco	2,297,123	For
Legg Mason	1,859,609	For
GMO	1,694,246	For
Brighthouse	1,614,259	For
Morgan Stanley	1,352,913	For
INVESTMENT CO OF AMERICA	1,214,318	For
Columbia Threadneedle	1,197,863	For
Equitable	1,186,576	For
AMCAP FUND	1,102,126	For
CAUSEWAY CAPITAL MANAGEMENT TRUST	1,032,543	For
HARRIS ASSOCIATES INVESTMENT TRUST	795,800	For
BNY Mellon	746,429	For
Lincoln Financial	683,174	For
American Century	637,210	For
NEW ECONOMY FUND	624,839	For

Showing the 25 largest of 116 asset managers. See all 116 in the interactive database.

6. Approve Discharge of Management Board for Fiscal Year 2023

CORPORATE GOVERNANCE

100% fund support · no official result

FOR 100%

The 116 asset managers below cast 100% of the shares they voted on this item FOR (164,434,579 for, 0 against).

FOR: 164,434,579 (100.0%)

Largest asset managers voting on “Approve Discharge of Management Board for Fiscal Year 2023” at SAP SE, 2023-2024
Asset manager	For	Vote
Capital Group	34,275,086	For
Vanguard	31,767,059	For
Fidelity	20,018,291	For
BlackRock	18,777,472	For
MFS	9,561,938	For
Goldman Sachs	6,316,766	For
Six Circles Trust	4,919,138	For
T. Rowe Price	4,086,804	For
TIAA	3,075,482	For
State Street	2,542,761	For
Invesco	2,297,123	For
Legg Mason	1,859,609	For
GMO	1,694,246	For
Brighthouse	1,614,259	For
Morgan Stanley	1,352,913	For
INVESTMENT CO OF AMERICA	1,214,318	For
Columbia Threadneedle	1,197,863	For
Equitable	1,186,576	For
AMCAP FUND	1,102,126	For
CAUSEWAY CAPITAL MANAGEMENT TRUST	1,032,543	For
HARRIS ASSOCIATES INVESTMENT TRUST	795,800	For
BNY Mellon	746,429	For
Lincoln Financial	683,174	For
American Century	637,210	For
NEW ECONOMY FUND	624,839	For

Showing the 25 largest of 116 asset managers. See all 116 in the interactive database.

7. Approve Discharge of Supervisory Board for Fiscal Year 2023

CORPORATE GOVERNANCE

100% fund support · no official result

FOR 100%

The 116 asset managers below cast 100% of the shares they voted on this item FOR (164,434,964 for, 0 against).

FOR: 164,434,964 (100.0%)

Largest asset managers voting on “Approve Discharge of Supervisory Board for Fiscal Year 2023” at SAP SE, 2023-2024
Asset manager	For	Vote
Capital Group	34,275,086	For
Vanguard	31,767,059	For
Fidelity	20,018,291	For
BlackRock	18,777,472	For
MFS	9,561,938	For
Goldman Sachs	6,316,766	For
Six Circles Trust	4,919,138	For
T. Rowe Price	4,086,804	For
TIAA	3,075,482	For
State Street	2,542,761	For
Invesco	2,297,123	For
Legg Mason	1,859,609	For
GMO	1,694,246	For
Brighthouse	1,614,259	For
Morgan Stanley	1,352,913	For
INVESTMENT CO OF AMERICA	1,214,318	For
Columbia Threadneedle	1,197,863	For
Equitable	1,186,576	For
AMCAP FUND	1,102,126	For
CAUSEWAY CAPITAL MANAGEMENT TRUST	1,032,543	For
HARRIS ASSOCIATES INVESTMENT TRUST	795,800	For
BNY Mellon	746,429	For
Lincoln Financial	683,174	For
American Century	637,210	For
NEW ECONOMY FUND	624,839	For

Showing the 25 largest of 116 asset managers. See all 116 in the interactive database.

8. Elect Aicha Evans to the Supervisory Board

DIRECTOR ELECTIONS

98% fund support · no official result

FOR 98%

The 116 asset managers below cast 98% of the shares they voted on this item FOR (160,563,602 for, 3,871,362 against).

FOR: 160,563,602 (97.6%)AGAINST: 3,871,362 (2.4%)

Largest asset managers voting on “Elect Aicha Evans to the Supervisory Board” at SAP SE, 2023-2024
Asset manager	For	Against	Vote
Capital Group	34,275,086	0	For
Vanguard	31,767,059	0	For
Fidelity	20,018,291	0	For
BlackRock	18,777,472	0	For
MFS	9,561,938	0	For
Goldman Sachs	6,316,766	0	For
Six Circles Trust	4,919,138	0	For
T. Rowe Price	4,086,804	0	For
TIAA	3,075,482	0	For
State Street	2,542,727	34	For
Invesco	2,297,123	0	For
Legg Mason	1,845,266	14,343	For
GMO	0	1,694,246	Against
Brighthouse	1,614,259	0	For
Morgan Stanley	1,347,814	5,099	For
INVESTMENT CO OF AMERICA	1,214,318	0	For
Columbia Threadneedle	1,197,863	0	For
Equitable	1,186,576	0	For
AMCAP FUND	1,102,126	0	For
CAUSEWAY CAPITAL MANAGEMENT TRUST	1,032,543	0	For
HARRIS ASSOCIATES INVESTMENT TRUST	795,800	0	For
BNY Mellon	746,429	0	For
Lincoln Financial	605,895	77,279	For
American Century	637,210	0	For
NEW ECONOMY FUND	624,839	0	For

Showing the 25 largest of 116 asset managers. See all 116 in the interactive database.

9. Elect Friederike Rotsch to the Supervisory Board

DIRECTOR ELECTIONS

97% fund support · no official result

FOR 97%

The 116 asset managers below cast 97% of the shares they voted on this item FOR (159,365,739 for, 5,069,225 against).

FOR: 159,365,739 (96.9%)AGAINST: 5,069,225 (3.1%)

Largest asset managers voting on “Elect Friederike Rotsch to the Supervisory Board” at SAP SE, 2023-2024
Asset manager	For	Against	Vote
Capital Group	34,275,086	0	For
Vanguard	31,767,059	0	For
Fidelity	20,018,291	0	For
BlackRock	18,777,472	0	For
MFS	9,561,938	0	For
Goldman Sachs	6,316,766	0	For
Six Circles Trust	4,919,138	0	For
T. Rowe Price	4,086,804	0	For
TIAA	3,075,482	0	For
State Street	2,542,727	34	For
Invesco	2,297,123	0	For
Legg Mason	1,845,266	14,343	For
GMO	0	1,694,246	Against
Brighthouse	1,614,259	0	For
Morgan Stanley	1,347,814	5,099	For
INVESTMENT CO OF AMERICA	1,214,318	0	For
Columbia Threadneedle	0	1,197,863	Against
Equitable	1,186,576	0	For
AMCAP FUND	1,102,126	0	For
CAUSEWAY CAPITAL MANAGEMENT TRUST	1,032,543	0	For
HARRIS ASSOCIATES INVESTMENT TRUST	795,800	0	For
BNY Mellon	746,429	0	For
Lincoln Financial	605,895	77,279	For
American Century	637,210	0	For
NEW ECONOMY FUND	624,839	0	For

Showing the 25 largest of 116 asset managers. See all 116 in the interactive database.

10. Elect Gerhard Oswald to the Supervisory Board

DIRECTOR ELECTIONS

95% fund support · no official result

FOR 95%

The 116 asset managers below cast 95% of the shares they voted on this item FOR (155,784,116 for, 8,650,848 against).

FOR: 155,784,116 (94.7%)AGAINST: 8,650,848 (5.3%)

Largest asset managers voting on “Elect Gerhard Oswald to the Supervisory Board” at SAP SE, 2023-2024
Asset manager	For	Against	Vote
Capital Group	34,275,086	0	For
Vanguard	31,767,059	0	For
Fidelity	20,018,291	0	For
BlackRock	18,777,472	0	For
MFS	9,561,938	0	For
Goldman Sachs	6,316,766	0	For
Six Circles Trust	4,919,138	0	For
T. Rowe Price	4,086,804	0	For
TIAA	3,075,482	0	For
State Street	2,542,759	2	For
Invesco	0	2,297,123	Against
Legg Mason	1,859,609	0	For
GMO	1,694,246	0	For
Brighthouse	129,736	1,484,523	Against
Morgan Stanley	1,347,814	5,099	For
INVESTMENT CO OF AMERICA	1,214,318	0	For
Columbia Threadneedle	0	1,197,863	Against
Equitable	1,058,455	128,121	For
AMCAP FUND	1,102,126	0	For
CAUSEWAY CAPITAL MANAGEMENT TRUST	1,032,543	0	For
HARRIS ASSOCIATES INVESTMENT TRUST	0	795,800	Against
BNY Mellon	746,429	0	For
Lincoln Financial	633,375	49,799	For
American Century	0	637,210	Against
NEW ECONOMY FUND	624,839	0	For

Showing the 25 largest of 116 asset managers. See all 116 in the interactive database.

11. Elect Pekka Ala-Pietilae to the Supervisory Board

DIRECTOR ELECTIONS

99.8% fund support · no official result

FOR 99.8%

The 116 asset managers below cast 99.8% of the shares they voted on this item FOR (164,262,224 for, 172,740 against).

FOR: 164,262,224 (99.9%)AGAINST: 172,740 (0.1%)

Largest asset managers voting on “Elect Pekka Ala-Pietilae to the Supervisory Board” at SAP SE, 2023-2024
Asset manager	For	Against	Vote
Capital Group	34,275,086	0	For
Vanguard	31,767,059	0	For
Fidelity	20,018,291	0	For
BlackRock	18,777,472	0	For
MFS	9,561,938	0	For
Goldman Sachs	6,316,766	0	For
Six Circles Trust	4,919,138	0	For
T. Rowe Price	4,086,804	0	For
TIAA	3,075,482	0	For
State Street	2,542,761	0	For
Invesco	2,297,123	0	For
Legg Mason	1,859,609	0	For
GMO	1,694,246	0	For
Brighthouse	1,614,259	0	For
Morgan Stanley	1,347,814	5,099	For
INVESTMENT CO OF AMERICA	1,214,318	0	For
Columbia Threadneedle	1,197,863	0	For
Equitable	1,186,576	0	For
AMCAP FUND	1,102,126	0	For
CAUSEWAY CAPITAL MANAGEMENT TRUST	1,032,543	0	For
HARRIS ASSOCIATES INVESTMENT TRUST	795,800	0	For
BNY Mellon	746,429	0	For
Lincoln Financial	683,174	0	For
American Century	637,210	0	For
NEW ECONOMY FUND	624,839	0	For

Showing the 25 largest of 116 asset managers. See all 116 in the interactive database.

12. Elect Ralf Herbrich to the Supervisory Board

DIRECTOR ELECTIONS

99.8% fund support · no official result

FOR 99.8%

The 116 asset managers below cast 99.8% of the shares they voted on this item FOR (164,262,224 for, 172,740 against).

FOR: 164,262,224 (99.9%)AGAINST: 172,740 (0.1%)

Largest asset managers voting on “Elect Ralf Herbrich to the Supervisory Board” at SAP SE, 2023-2024
Asset manager	For	Against	Vote
Capital Group	34,275,086	0	For
Vanguard	31,767,059	0	For
Fidelity	20,018,291	0	For
BlackRock	18,777,472	0	For
MFS	9,561,938	0	For
Goldman Sachs	6,316,766	0	For
Six Circles Trust	4,919,138	0	For
T. Rowe Price	4,086,804	0	For
TIAA	3,075,482	0	For
State Street	2,542,761	0	For
Invesco	2,297,123	0	For
Legg Mason	1,859,609	0	For
GMO	1,694,246	0	For
Brighthouse	1,614,259	0	For
Morgan Stanley	1,347,814	5,099	For
INVESTMENT CO OF AMERICA	1,214,318	0	For
Columbia Threadneedle	1,197,863	0	For
Equitable	1,186,576	0	For
AMCAP FUND	1,102,126	0	For
CAUSEWAY CAPITAL MANAGEMENT TRUST	1,032,543	0	For
HARRIS ASSOCIATES INVESTMENT TRUST	795,800	0	For
BNY Mellon	746,429	0	For
Lincoln Financial	683,174	0	For
American Century	637,210	0	For
NEW ECONOMY FUND	624,839	0	For

Showing the 25 largest of 116 asset managers. See all 116 in the interactive database.

13. Ratify BDO AG as Auditors for Fiscal Year 2024 and as Auditors of Sustainability Reporting for Fiscal Year 2024

AUDIT-RELATED

100% fund support · no official result

FOR 100%

The 116 asset managers below cast 100% of the shares they voted on this item FOR (164,434,964 for, 0 against).

FOR: 164,434,964 (100.0%)

Largest asset managers voting on “Ratify BDO AG as Auditors for Fiscal Year 2024 and as Auditors of Sustainability Reporting for Fiscal Year 202” at SAP SE, 2023-2024
Asset manager	For	Vote
Capital Group	34,275,086	For
Vanguard	31,767,059	For
Fidelity	20,018,291	For
BlackRock	18,777,472	For
MFS	9,561,938	For
Goldman Sachs	6,316,766	For
Six Circles Trust	4,919,138	For
T. Rowe Price	4,086,804	For
TIAA	3,075,482	For
State Street	2,542,761	For
Invesco	2,297,123	For
Legg Mason	1,859,609	For
GMO	1,694,246	For
Brighthouse	1,614,259	For
Morgan Stanley	1,352,913	For
INVESTMENT CO OF AMERICA	1,214,318	For
Columbia Threadneedle	1,197,863	For
Equitable	1,186,576	For
AMCAP FUND	1,102,126	For
CAUSEWAY CAPITAL MANAGEMENT TRUST	1,032,543	For
HARRIS ASSOCIATES INVESTMENT TRUST	795,800	For
BNY Mellon	746,429	For
Lincoln Financial	683,174	For
American Century	637,210	For
NEW ECONOMY FUND	624,839	For

Showing the 25 largest of 116 asset managers. See all 116 in the interactive database.

14. Resolution on the compensation of the Supervisory Board members under amendment of Article 16 of the Articles of Incorporation

COMPENSATION

Combines 4 wordings of this item as funds reported it.

99.5% fund support · no official result

FOR 40%ABSTAIN 60%

The 74 asset managers below cast 99.5% of the shares they voted on this item FOR (2,617,573 for, 13,045 against).

FOR: 2,617,573 (39.7%)AGAINST: 13,045 (0.2%)ABSTAIN: 3,949,561 (59.9%)NOT VOTED: 11,356 (0.2%)

Largest asset managers voting on “Resolution on the compensation of the Supervisory Board members under amendment of Article 16 of the Articles ” at SAP SE, 2023-2024
Asset manager	For	Against	Abstain	Vote
WINDACRE PARTNERSHIP LLC	0	0	3,582,500	Abstain
HARDING LOEVNER FUNDS INC	1,695,271	0	0	For
CRAWFORD INVESTMENT COUNSEL INC	0	0	358,424	Abstain
BECKER CAPITAL MANAGEMENT INC	203,816	0	0	For
Cardinal Capital Management, Inc.	150,365	0	0	For
UNITED CAPITAL FINANCIAL ADVISORS, LLC	144,767	0	0	For
BUFFALO FUNDS	87,391	0	0	For
Janney Montgomery Scott LLC	84,692	0	0	For
MARSICO INVESTMENT FUND	46,294	0	0	For
Night Owl Capital Management, LLC	41,598	0	0	For
TRUST FOR PROFESSIONAL MANAGERS	32,944	0	0	For
Morningstar Funds Trust	25,621	0	0	For
Ultimus Managers Trust	12,249	0	3,632	For
SATURNA INVESTMENT TRUST	14,200	0	0	For
HOMESTEAD FUNDS INC	13,771	0	0	For
Naviter Wealth, LLC	13,517	0	0	For
LOCKHEED MARTIN INVESTMENT MANAGEMENT CO	0	12,890	0	Against
ADVISORS SERIES TRUST	0	0	0	Not Voted
EXENCIAL WEALTH ADVISORS, LLC	10,401	0	0	For
SevenBridge Financial Group, LLC	7,415	0	0	For
Gabelli	6,300	0	0	For
MITCHELL & PAHL PRIVATE WEALTH, LLC	0	0	5,005	Abstain
SHELTON WEALTH MANAGEMENT, LLC	3,660	0	0	For
CITY NATIONAL ROCHDALE FUNDS	3,372	0	0	For
Manager Directed Portfolios	2,075	0	0	For

Showing the 25 largest of 74 asset managers. See all 74 in the interactive database.

15. APPROVAL OF THE COMPENSATION REPORT FOR FISCAL YEAR 2023

COMPENSATION

95% fund support · no official result

FOR 95%

The 73 asset managers below cast 95% of the shares they voted on this item FOR (19,014,791 for, 1,006,863 against).

FOR: 19,014,791 (94.5%)AGAINST: 1,006,863 (5.0%)ABSTAIN: 21,211 (0.1%)NOT VOTED: 75,850 (0.4%)

Largest asset managers voting on “APPROVAL OF THE COMPENSATION REPORT FOR FISCAL YEAR 2023” at SAP SE, 2023-2024
Asset manager	For	Against	Vote
EdgePoint Investment Group Inc.	2,887,244	0	For
Egerton Capital (UK) LLP	2,413,397	0	For
STATE FARM MUTUAL AUTOMOBILE INSURANCE CO	2,313,200	0	For
JPMorgan	2,226,181	0	For
BAILLIE GIFFORD OVERSEAS LTD	1,884,742	0	For
Northern Trust	1,513,150	89,882	For
Korea Investment CORP	0	911,833	Against
1832 Asset Management L.P.	909,398	0	For
Jackson National	733,587	0	For
SEQUOIA FUND INC	713,889	0	For
John Hancock	514,676	0	For
BAILLIE GIFFORD FUNDS	438,912	0	For
BBH Trust	292,302	0	For
South Dakota Investment Council	271,771	0	For
LETKO, BROSSEAU & ASSOCIATES INC	264,863	0	For
Siemens Fonds Invest GmbH	260,747	0	For
BAILLIE GIFFORD & CO LTD	259,959	0	For
Bridge Builder Trust	183,890	0	For
Natixis	126,490	0	For
JARISLOWSKY, FRASER Ltd	112,730	0	For
Allianz	89,545	0	For
MARSICO CAPITAL MANAGEMENT LLC	0	0	Not Voted
Polaris Capital Management, LLC	58,505	0	For
Guardian Variable Products Trust	56,370	0	For
Baillie Gifford Investment Management (Europe) Ltd	47,383	0	For

Showing the 25 largest of 73 asset managers. See all 73 in the interactive database.

16. APPOINTMENT OF THE AUDITORS OF THE ANNUAL FINANCIAL STATEMENTS AND GROUP ANNUAL FINANCIAL STATEMENTS AND OF THE AUDITORS OF THE SUSTAINABILITY REPORTING FOR FISCAL YEAR 2024

AUDIT-RELATED

Combines 2 wordings of this item as funds reported it.

99.9% fund support · no official result

FOR 99.5%

The 55 asset managers below cast 99.9% of the shares they voted on this item FOR (7,054,179 for, 200 against).

FOR: 7,054,179 (99.6%)AGAINST: 200 (0.0%)ABSTAIN: 3,632 (0.1%)NOT VOTED: 25,093 (0.4%)

Largest asset managers voting on “APPOINTMENT OF THE AUDITORS OF THE ANNUAL FINANCIAL STATEMENTS AND GROUP ANNUAL FINANCIAL STATEMENTS AND OF TH” at SAP SE, 2023-2024
Asset manager	For	Vote
HARDING LOEVNER FUNDS INC	1,695,271	For
JPMorgan	1,586,042	For
Jackson National	733,587	For
SEQUOIA FUND INC	713,889	For
John Hancock	514,676	For
BAILLIE GIFFORD FUNDS	438,912	For
BBH Trust	292,302	For
Bridge Builder Trust	183,890	For
Natixis	126,448	For
Allianz	89,545	For
BUFFALO FUNDS	87,391	For
MARSICO INVESTMENT FUND	46,294	For
Guardian Variable Products Trust	56,370	For
TRUST FOR PROFESSIONAL MANAGERS	45,974	For
Innovator ETFs Trust	41,829	For
Calamos	41,522	For
Resolute Capital Asset Partners LLC	35,000	For
CARILLON SERIES TRUST	27,209	For
SCHWARTZ INVESTMENT TRUST	26,000	For
Morningstar Funds Trust	25,621	For
Harbor ETF Trust	23,665	For
TOUCHSTONE STRATEGIC TRUST	22,930	For
PFM Multi-Manager Series Trust	22,022	For
Advisors' Inner Circle Fund III	18,300	For
ADVISORS' INNER CIRCLE FUND	16,000	For

Showing the 25 largest of 55 asset managers. See all 55 in the interactive database.

17. ELECTION OF SUPERVISORY BOARD MEMBER: AICHA EVANS

DIRECTOR ELECTIONS

95% fund support · no official result

FOR 95%

The 54 asset managers below cast 95% of the shares they voted on this item FOR (6,702,850 for, 316,529 against).

FOR: 6,702,850 (95.1%)AGAINST: 316,529 (4.5%)ABSTAIN: 3,632 (0.1%)NOT VOTED: 25,093 (0.4%)

Largest asset managers voting on “ELECTION OF SUPERVISORY BOARD MEMBER: AICHA EVANS” at SAP SE, 2023-2024
Asset manager	For	Against	Abstain	Vote
HARDING LOEVNER FUNDS INC	1,695,271	0	0	For
JPMorgan	1,586,042	0	0	For
Jackson National	690,778	42,809	0	For
SEQUOIA FUND INC	713,889	0	0	For
John Hancock	352,615	162,061	0	For
BAILLIE GIFFORD FUNDS	438,912	0	0	For
BBH Trust	292,302	0	0	For
Bridge Builder Trust	183,890	0	0	For
Natixis	14,789	111,659	0	Against
Allianz	89,545	0	0	For
BUFFALO FUNDS	87,391	0	0	For
MARSICO INVESTMENT FUND	46,294	0	0	For
Guardian Variable Products Trust	56,370	0	0	For
TRUST FOR PROFESSIONAL MANAGERS	45,974	0	0	For
Innovator ETFs Trust	41,829	0	0	For
Calamos	41,522	0	0	For
CARILLON SERIES TRUST	27,209	0	0	For
SCHWARTZ INVESTMENT TRUST	26,000	0	0	For
Morningstar Funds Trust	25,621	0	0	For
Harbor ETF Trust	23,665	0	0	For
TOUCHSTONE STRATEGIC TRUST	22,930	0	0	For
PFM Multi-Manager Series Trust	22,022	0	0	For
Advisors' Inner Circle Fund III	18,300	0	0	For
ADVISORS' INNER CIRCLE FUND	16,000	0	0	For
Ultimus Managers Trust	12,249	0	3,632	For

Showing the 25 largest of 54 asset managers. See all 54 in the interactive database.

18. ELECTION OF SUPERVISORY BOARD MEMBER: DR. FRIEDERIKE ROTSCH

DIRECTOR ELECTIONS

95% fund support · no official result

FOR 95%

The 54 asset managers below cast 95% of the shares they voted on this item FOR (6,688,650 for, 330,729 against).

FOR: 6,688,650 (94.9%)AGAINST: 330,729 (4.7%)ABSTAIN: 3,632 (0.1%)NOT VOTED: 25,093 (0.4%)

Largest asset managers voting on “ELECTION OF SUPERVISORY BOARD MEMBER: DR. FRIEDERIKE ROTSCH” at SAP SE, 2023-2024
Asset manager	For	Against	Abstain	Vote
HARDING LOEVNER FUNDS INC	1,695,271	0	0	For
JPMorgan	1,586,042	0	0	For
Jackson National	690,778	42,809	0	For
SEQUOIA FUND INC	713,889	0	0	For
John Hancock	352,615	162,061	0	For
BAILLIE GIFFORD FUNDS	438,912	0	0	For
BBH Trust	292,302	0	0	For
Bridge Builder Trust	183,890	0	0	For
Natixis	14,789	111,659	0	Against
Allianz	89,545	0	0	For
BUFFALO FUNDS	87,391	0	0	For
MARSICO INVESTMENT FUND	46,294	0	0	For
Guardian Variable Products Trust	56,370	0	0	For
TRUST FOR PROFESSIONAL MANAGERS	45,974	0	0	For
Innovator ETFs Trust	41,829	0	0	For
Calamos	41,522	0	0	For
CARILLON SERIES TRUST	27,209	0	0	For
SCHWARTZ INVESTMENT TRUST	26,000	0	0	For
Morningstar Funds Trust	25,621	0	0	For
Harbor ETF Trust	23,665	0	0	For
TOUCHSTONE STRATEGIC TRUST	22,930	0	0	For
PFM Multi-Manager Series Trust	22,022	0	0	For
Advisors' Inner Circle Fund III	18,300	0	0	For
ADVISORS' INNER CIRCLE FUND	16,000	0	0	For
Ultimus Managers Trust	12,249	0	3,632	For

Showing the 25 largest of 54 asset managers. See all 54 in the interactive database.

19. ELECTION OF SUPERVISORY BOARD MEMBER: GERHARD OSWALD

DIRECTOR ELECTIONS

71% fund support · no official result

FOR 70%AGAINST 29%

The 54 asset managers below cast 71% of the shares they voted on this item FOR (4,957,866 for, 2,061,513 against).

FOR: 4,957,866 (70.3%)AGAINST: 2,061,513 (29.2%)ABSTAIN: 3,632 (0.1%)NOT VOTED: 25,093 (0.4%)

Largest asset managers voting on “ELECTION OF SUPERVISORY BOARD MEMBER: GERHARD OSWALD” at SAP SE, 2023-2024
Asset manager	For	Against	Abstain	Vote
HARDING LOEVNER FUNDS INC	1,695,271	0	0	For
JPMorgan	0	1,586,042	0	Against
Jackson National	435,500	298,087	0	For
SEQUOIA FUND INC	713,889	0	0	For
John Hancock	514,676	0	0	For
BAILLIE GIFFORD FUNDS	438,912	0	0	For
BBH Trust	292,302	0	0	For
Bridge Builder Trust	52,556	131,334	0	Against
Natixis	111,659	14,789	0	For
Allianz	89,545	0	0	For
BUFFALO FUNDS	87,391	0	0	For
MARSICO INVESTMENT FUND	46,294	0	0	For
Guardian Variable Products Trust	50,386	5,984	0	For
TRUST FOR PROFESSIONAL MANAGERS	45,974	0	0	For
Innovator ETFs Trust	41,829	0	0	For
Calamos	41,522	0	0	For
CARILLON SERIES TRUST	27,209	0	0	For
SCHWARTZ INVESTMENT TRUST	26,000	0	0	For
Morningstar Funds Trust	25,621	0	0	For
Harbor ETF Trust	23,665	0	0	For
TOUCHSTONE STRATEGIC TRUST	22,930	0	0	For
PFM Multi-Manager Series Trust	2,078	19,944	0	Against
Advisors' Inner Circle Fund III	18,300	0	0	For
ADVISORS' INNER CIRCLE FUND	16,000	0	0	For
Ultimus Managers Trust	12,249	0	3,632	For

Showing the 25 largest of 54 asset managers. See all 54 in the interactive database.

20. ELECTION OF SUPERVISORY BOARD MEMBER: DR. H. C. MULT. PEKKA ALA-PIETILA

DIRECTOR ELECTIONS

Combines 4 wordings of this item as funds reported it.

99.7% fund support · no official result

FOR 99.3%

The 53 asset managers below cast 99.7% of the shares they voted on this item FOR (7,004,328 for, 14,200 against).

FOR: 7,004,328 (99.4%)AGAINST: 14,200 (0.2%)ABSTAIN: 3,632 (0.1%)NOT VOTED: 25,093 (0.4%)

Largest asset managers voting on “ELECTION OF SUPERVISORY BOARD MEMBER: DR. H. C. MULT. PEKKA ALA-PIETILA” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
HARDING LOEVNER FUNDS INC	1,695,271	0	For
JPMorgan	1,586,042	0	For
Jackson National	733,587	0	For
SEQUOIA FUND INC	713,889	0	For
John Hancock	514,676	0	For
BAILLIE GIFFORD FUNDS	438,912	0	For
BBH Trust	292,302	0	For
Bridge Builder Trust	183,890	0	For
Natixis	126,448	0	For
Allianz	89,545	0	For
BUFFALO FUNDS	87,391	0	For
MARSICO INVESTMENT FUND	46,294	0	For
Guardian Variable Products Trust	56,370	0	For
TRUST FOR PROFESSIONAL MANAGERS	45,974	0	For
Innovator ETFs Trust	41,829	0	For
Calamos	41,522	0	For
CARILLON SERIES TRUST	27,209	0	For
SCHWARTZ INVESTMENT TRUST	26,000	0	For
Morningstar Funds Trust	25,621	0	For
Harbor ETF Trust	23,665	0	For
TOUCHSTONE STRATEGIC TRUST	22,930	0	For
PFM Multi-Manager Series Trust	22,022	0	For
Advisors' Inner Circle Fund III	18,300	0	For
ADVISORS' INNER CIRCLE FUND	16,000	0	For
Ultimus Managers Trust	12,249	3,632	For

Showing the 25 largest of 53 asset managers. See all 53 in the interactive database.

21. ELECTION OF SUPERVISORY BOARD MEMBER: PROF. DR. RALF HERBRICH

DIRECTOR ELECTIONS

100% fund support · no official result

FOR 99.5%

The 53 asset managers below cast 100% of the shares they voted on this item FOR (7,018,528 for, 0 against).

FOR: 7,018,528 (99.6%)ABSTAIN: 3,632 (0.1%)NOT VOTED: 25,093 (0.4%)

Largest asset managers voting on “ELECTION OF SUPERVISORY BOARD MEMBER: PROF. DR. RALF HERBRICH” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
HARDING LOEVNER FUNDS INC	1,695,271	0	For
JPMorgan	1,586,042	0	For
Jackson National	733,587	0	For
SEQUOIA FUND INC	713,889	0	For
John Hancock	514,676	0	For
BAILLIE GIFFORD FUNDS	438,912	0	For
BBH Trust	292,302	0	For
Bridge Builder Trust	183,890	0	For
Natixis	126,448	0	For
Allianz	89,545	0	For
BUFFALO FUNDS	87,391	0	For
MARSICO INVESTMENT FUND	46,294	0	For
Guardian Variable Products Trust	56,370	0	For
TRUST FOR PROFESSIONAL MANAGERS	45,974	0	For
Innovator ETFs Trust	41,829	0	For
Calamos	41,522	0	For
CARILLON SERIES TRUST	27,209	0	For
SCHWARTZ INVESTMENT TRUST	26,000	0	For
Morningstar Funds Trust	25,621	0	For
Harbor ETF Trust	23,665	0	For
TOUCHSTONE STRATEGIC TRUST	22,930	0	For
PFM Multi-Manager Series Trust	22,022	0	For
Advisors' Inner Circle Fund III	18,300	0	For
ADVISORS' INNER CIRCLE FUND	16,000	0	For
Ultimus Managers Trust	12,249	3,632	For

Showing the 25 largest of 53 asset managers. See all 53 in the interactive database.

22. COMPENSATION OF THE SUPERVISORY BOARD MEMBERS UNDER AMENDMENT OF ARTICLE 16 OF THE ARTICLES OF INCORPORATION

DIRECTOR ELECTIONS

100% fund support · no official result

FOR 99.5%

The 39 asset managers below cast 100% of the shares they voted on this item FOR (7,519,762 for, 0 against).

FOR: 7,519,762 (99.5%)ABSTAIN: 21,211 (0.3%)NOT VOTED: 13,737 (0.2%)

Largest asset managers voting on “COMPENSATION OF THE SUPERVISORY BOARD MEMBERS UNDER AMENDMENT OF ARTICLE 16 OF THE ARTICLES OF INCORPORATION” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
Egerton Capital (UK) LLP	2,413,397	0	For
JPMorgan	1,586,042	0	For
Jackson National	733,587	0	For
SEQUOIA FUND INC	713,889	0	For
John Hancock	514,676	0	For
BAILLIE GIFFORD FUNDS	438,912	0	For
BBH Trust	292,302	0	For
Bridge Builder Trust	183,890	0	For
Natixis	126,448	0	For
Allianz	89,545	0	For
Guardian Variable Products Trust	56,370	0	For
Innovator ETFs Trust	41,694	0	For
Calamos	41,144	0	For
LOCKHEED MARTIN INVESTMENT MANAGEMENT CO	35,630	0	For
CARILLON SERIES TRUST	27,209	0	For
SCHWARTZ INVESTMENT TRUST	26,000	0	For
Harbor ETF Trust	23,108	0	For
TOUCHSTONE STRATEGIC TRUST	22,930	0	For
PFM Multi-Manager Series Trust	22,022	0	For
Apollo Management Holdings, L.P.	0	21,211	Abstain
Advisors' Inner Circle Fund III	18,300	0	For
ADVISORS' INNER CIRCLE FUND	16,000	0	For
MARSICO INVESTMENT FUND	0	0	Not Voted
TRUST FOR PROFESSIONAL MANAGERS	13,030	0	For
Listed Funds Trust	11,451	0	For

Showing the 25 largest of 39 asset managers. See all 39 in the interactive database.

23. AMENDMENT OF ARTICLE 18 (3) OF THE ARTICLES OF INCORPORATION

CORPORATE GOVERNANCE

100% fund support · no official result

FOR 99.7%

The 36 asset managers below cast 100% of the shares they voted on this item FOR (5,070,735 for, 0 against).

FOR: 5,070,735 (99.7%)NOT VOTED: 13,737 (0.3%)

Largest asset managers voting on “AMENDMENT OF ARTICLE 18 (3) OF THE ARTICLES OF INCORPORATION” at SAP SE, 2023-2024
Asset manager	For	Vote
JPMorgan	1,586,042	For
Jackson National	733,587	For
SEQUOIA FUND INC	713,889	For
John Hancock	514,676	For
BAILLIE GIFFORD FUNDS	438,912	For
BBH Trust	292,302	For
Bridge Builder Trust	183,890	For
Natixis	126,448	For
Allianz	89,545	For
Guardian Variable Products Trust	56,370	For
Innovator ETFs Trust	41,694	For
Calamos	41,144	For
CARILLON SERIES TRUST	27,209	For
SCHWARTZ INVESTMENT TRUST	26,000	For
Harbor ETF Trust	23,108	For
TOUCHSTONE STRATEGIC TRUST	22,930	For
PFM Multi-Manager Series Trust	22,022	For
Advisors' Inner Circle Fund III	18,300	For
ADVISORS' INNER CIRCLE FUND	16,000	For
MARSICO INVESTMENT FUND	0	Not Voted
TRUST FOR PROFESSIONAL MANAGERS	13,030	For
Listed Funds Trust	11,451	For
LKCM Funds	11,333	For
CPG Cooper Square International Equity, LLC	9,969	For
Loomis Sayles	7,982	For

Showing the 25 largest of 36 asset managers. See all 36 in the interactive database.

24. APPROPRIATION OF THE RETAINED EARNINGS FOR FISCAL YEAR 2023

AUDIT-RELATED

100% fund support · no official result

FOR 99.7%

The 36 asset managers below cast 100% of the shares they voted on this item FOR (5,070,735 for, 0 against).

FOR: 5,070,735 (99.7%)NOT VOTED: 13,737 (0.3%)

Largest asset managers voting on “APPROPRIATION OF THE RETAINED EARNINGS FOR FISCAL YEAR 2023” at SAP SE, 2023-2024
Asset manager	For	Vote
JPMorgan	1,586,042	For
Jackson National	733,587	For
SEQUOIA FUND INC	713,889	For
John Hancock	514,676	For
BAILLIE GIFFORD FUNDS	438,912	For
BBH Trust	292,302	For
Bridge Builder Trust	183,890	For
Natixis	126,448	For
Allianz	89,545	For
Guardian Variable Products Trust	56,370	For
Innovator ETFs Trust	41,694	For
Calamos	41,144	For
CARILLON SERIES TRUST	27,209	For
SCHWARTZ INVESTMENT TRUST	26,000	For
Harbor ETF Trust	23,108	For
TOUCHSTONE STRATEGIC TRUST	22,930	For
PFM Multi-Manager Series Trust	22,022	For
Advisors' Inner Circle Fund III	18,300	For
ADVISORS' INNER CIRCLE FUND	16,000	For
MARSICO INVESTMENT FUND	0	Not Voted
TRUST FOR PROFESSIONAL MANAGERS	13,030	For
Listed Funds Trust	11,451	For
LKCM Funds	11,333	For
CPG Cooper Square International Equity, LLC	9,969	For
Loomis Sayles	7,982	For

Showing the 25 largest of 36 asset managers. See all 36 in the interactive database.

25. FORMAL APPROVAL OF THE ACTS OF THE EXECUTIVE BOARD IN FISCAL YEAR 2023

CORPORATE GOVERNANCE

100% fund support · no official result

FOR 99.7%

The 36 asset managers below cast 100% of the shares they voted on this item FOR (5,070,735 for, 0 against).

FOR: 5,070,735 (99.7%)NOT VOTED: 13,737 (0.3%)

Largest asset managers voting on “FORMAL APPROVAL OF THE ACTS OF THE EXECUTIVE BOARD IN FISCAL YEAR 2023” at SAP SE, 2023-2024
Asset manager	For	Vote
JPMorgan	1,586,042	For
Jackson National	733,587	For
SEQUOIA FUND INC	713,889	For
John Hancock	514,676	For
BAILLIE GIFFORD FUNDS	438,912	For
BBH Trust	292,302	For
Bridge Builder Trust	183,890	For
Natixis	126,448	For
Allianz	89,545	For
Guardian Variable Products Trust	56,370	For
Innovator ETFs Trust	41,694	For
Calamos	41,144	For
CARILLON SERIES TRUST	27,209	For
SCHWARTZ INVESTMENT TRUST	26,000	For
Harbor ETF Trust	23,108	For
TOUCHSTONE STRATEGIC TRUST	22,930	For
PFM Multi-Manager Series Trust	22,022	For
Advisors' Inner Circle Fund III	18,300	For
ADVISORS' INNER CIRCLE FUND	16,000	For
MARSICO INVESTMENT FUND	0	Not Voted
TRUST FOR PROFESSIONAL MANAGERS	13,030	For
Listed Funds Trust	11,451	For
LKCM Funds	11,333	For
CPG Cooper Square International Equity, LLC	9,969	For
Loomis Sayles	7,982	For

Showing the 25 largest of 36 asset managers. See all 36 in the interactive database.

26. FORMAL APPROVAL OF THE ACTS OF THE SUPERVISORY BOARD IN FISCAL YEAR 2023

CORPORATE GOVERNANCE

100% fund support · no official result

FOR 99.7%

The 36 asset managers below cast 100% of the shares they voted on this item FOR (5,070,735 for, 0 against).

FOR: 5,070,735 (99.7%)NOT VOTED: 13,737 (0.3%)

Largest asset managers voting on “FORMAL APPROVAL OF THE ACTS OF THE SUPERVISORY BOARD IN FISCAL YEAR 2023” at SAP SE, 2023-2024
Asset manager	For	Vote
JPMorgan	1,586,042	For
Jackson National	733,587	For
SEQUOIA FUND INC	713,889	For
John Hancock	514,676	For
BAILLIE GIFFORD FUNDS	438,912	For
BBH Trust	292,302	For
Bridge Builder Trust	183,890	For
Natixis	126,448	For
Allianz	89,545	For
Guardian Variable Products Trust	56,370	For
Innovator ETFs Trust	41,694	For
Calamos	41,144	For
CARILLON SERIES TRUST	27,209	For
SCHWARTZ INVESTMENT TRUST	26,000	For
Harbor ETF Trust	23,108	For
TOUCHSTONE STRATEGIC TRUST	22,930	For
PFM Multi-Manager Series Trust	22,022	For
Advisors' Inner Circle Fund III	18,300	For
ADVISORS' INNER CIRCLE FUND	16,000	For
MARSICO INVESTMENT FUND	0	Not Voted
TRUST FOR PROFESSIONAL MANAGERS	13,030	For
Listed Funds Trust	11,451	For
LKCM Funds	11,333	For
CPG Cooper Square International Equity, LLC	9,969	For
Loomis Sayles	7,982	For

Showing the 25 largest of 36 asset managers. See all 36 in the interactive database.

27. RESOLUTION ON THE FORMAL APPROVAL OF THE ACTS OF THE EXECUTIVE BOARD IN FISCAL YEAR 2023

CORPORATE GOVERNANCE

Combines 2 wordings of this item as funds reported it.

100% fund support · no official result

FOR 99.2%

The 26 asset managers below cast 100% of the shares they voted on this item FOR (1,948,689 for, 0 against).

FOR: 1,948,689 (99.2%)ABSTAIN: 3,632 (0.2%)NOT VOTED: 11,356 (0.6%)

Largest asset managers voting on “RESOLUTION ON THE FORMAL APPROVAL OF THE ACTS OF THE EXECUTIVE BOARD IN FISCAL YEAR 2023” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
HARDING LOEVNER FUNDS INC	1,695,271	0	For
BUFFALO FUNDS	87,391	0	For
MARSICO INVESTMENT FUND	46,294	0	For
TRUST FOR PROFESSIONAL MANAGERS	32,944	0	For
Morningstar Funds Trust	25,621	0	For
Ultimus Managers Trust	12,249	3,632	For
SATURNA INVESTMENT TRUST	14,200	0	For
HOMESTEAD FUNDS INC	13,771	0	For
ADVISORS SERIES TRUST	0	0	Not Voted
Gabelli	6,300	0	For
CITY NATIONAL ROCHDALE FUNDS	3,372	0	For
Manager Directed Portfolios	2,075	0	For
REYNOLDS FUNDS INC	1,750	0	For
ETF Series Solutions	1,295	0	For
HARBOR FUNDS	1,294	0	For
Decatur Capital Management, Inc.	951	0	For
Advisors Preferred Trust	851	0	For
Gateway Trust	589	0	For
Harbor ETF Trust	557	0	For
Pacer Funds Trust	506	0	For
Calamos	378	0	For
Boltwood Capital Management	375	0	For
Multi-Select Securities Fund for Puerto Rico Residents	275	0	For
Evernest Financial Advisors, LLC	200	0	For
Innovator ETFs Trust	135	0	For

Showing the 25 largest of 26 asset managers. See all 26 in the interactive database.

28. RESOLUTION ON THE APPROPRIATION OF THE RETAINED EARNINGS FOR FISCAL YEAR 2023

OTHER

Combines 2 wordings of this item as funds reported it.

100% fund support · no official result

FOR 99.2%

The 25 asset managers below cast 100% of the shares they voted on this item FOR (1,948,644 for, 0 against).

FOR: 1,948,644 (99.2%)ABSTAIN: 3,632 (0.2%)NOT VOTED: 11,356 (0.6%)

Largest asset managers voting on “RESOLUTION ON THE APPROPRIATION OF THE RETAINED EARNINGS FOR FISCAL YEAR 2023” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
HARDING LOEVNER FUNDS INC	1,695,271	0	For
BUFFALO FUNDS	87,391	0	For
MARSICO INVESTMENT FUND	46,294	0	For
TRUST FOR PROFESSIONAL MANAGERS	32,944	0	For
Morningstar Funds Trust	25,621	0	For
Ultimus Managers Trust	12,249	3,632	For
SATURNA INVESTMENT TRUST	14,200	0	For
HOMESTEAD FUNDS INC	13,771	0	For
ADVISORS SERIES TRUST	0	0	Not Voted
Gabelli	6,300	0	For
CITY NATIONAL ROCHDALE FUNDS	3,372	0	For
Manager Directed Portfolios	2,075	0	For
REYNOLDS FUNDS INC	1,750	0	For
ETF Series Solutions	1,295	0	For
HARBOR FUNDS	1,294	0	For
Decatur Capital Management, Inc.	951	0	For
Advisors Preferred Trust	851	0	For
Gateway Trust	589	0	For
Harbor ETF Trust	557	0	For
Pacer Funds Trust	506	0	For
Calamos	378	0	For
Boltwood Capital Management	375	0	For
Multi-Select Securities Fund for Puerto Rico Residents	275	0	For
Evernest Financial Advisors, LLC	200	0	For
Innovator ETFs Trust	135	0	For

29. RESOLUTION ON THE FORMAL APPROVAL OF THE ACTS OF THE SUPERVISORY BOARD IN FISCAL YEAR 2023

CORPORATE GOVERNANCE

Combines 2 wordings of this item as funds reported it.

100% fund support · no official result

FOR 99.2%

The 25 asset managers below cast 100% of the shares they voted on this item FOR (1,948,644 for, 0 against).

FOR: 1,948,644 (99.2%)ABSTAIN: 3,632 (0.2%)NOT VOTED: 11,356 (0.6%)

Largest asset managers voting on “RESOLUTION ON THE FORMAL APPROVAL OF THE ACTS OF THE SUPERVISORY BOARD IN FISCAL YEAR 2023” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
HARDING LOEVNER FUNDS INC	1,695,271	0	For
BUFFALO FUNDS	87,391	0	For
MARSICO INVESTMENT FUND	46,294	0	For
TRUST FOR PROFESSIONAL MANAGERS	32,944	0	For
Morningstar Funds Trust	25,621	0	For
Ultimus Managers Trust	12,249	3,632	For
SATURNA INVESTMENT TRUST	14,200	0	For
HOMESTEAD FUNDS INC	13,771	0	For
ADVISORS SERIES TRUST	0	0	Not Voted
Gabelli	6,300	0	For
CITY NATIONAL ROCHDALE FUNDS	3,372	0	For
Manager Directed Portfolios	2,075	0	For
REYNOLDS FUNDS INC	1,750	0	For
ETF Series Solutions	1,295	0	For
HARBOR FUNDS	1,294	0	For
Decatur Capital Management, Inc.	951	0	For
Advisors Preferred Trust	851	0	For
Gateway Trust	589	0	For
Harbor ETF Trust	557	0	For
Pacer Funds Trust	506	0	For
Calamos	378	0	For
Boltwood Capital Management	375	0	For
Multi-Select Securities Fund for Puerto Rico Residents	275	0	For
Evernest Financial Advisors, LLC	200	0	For
Innovator ETFs Trust	135	0	For

30. RESOLUTION ON THE AMENDMENT OF ARTICLE 18 (3) OF THE ARTICLES OF INCORPORATION

SHAREHOLDER RIGHTS AND DEFENSES

Combines 2 wordings of this item as funds reported it.

100% fund support · no official result

FOR 99.2%

The 25 asset managers below cast 100% of the shares they voted on this item FOR (1,948,644 for, 0 against).

FOR: 1,948,644 (99.2%)ABSTAIN: 3,632 (0.2%)NOT VOTED: 11,356 (0.6%)

Largest asset managers voting on “RESOLUTION ON THE AMENDMENT OF ARTICLE 18 (3) OF THE ARTICLES OF INCORPORATION” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
HARDING LOEVNER FUNDS INC	1,695,271	0	For
BUFFALO FUNDS	87,391	0	For
MARSICO INVESTMENT FUND	46,294	0	For
TRUST FOR PROFESSIONAL MANAGERS	32,944	0	For
Morningstar Funds Trust	25,621	0	For
Ultimus Managers Trust	12,249	3,632	For
SATURNA INVESTMENT TRUST	14,200	0	For
HOMESTEAD FUNDS INC	13,771	0	For
ADVISORS SERIES TRUST	0	0	Not Voted
Gabelli	6,300	0	For
CITY NATIONAL ROCHDALE FUNDS	3,372	0	For
Manager Directed Portfolios	2,075	0	For
REYNOLDS FUNDS INC	1,750	0	For
ETF Series Solutions	1,295	0	For
HARBOR FUNDS	1,294	0	For
Decatur Capital Management, Inc.	951	0	For
Advisors Preferred Trust	851	0	For
Gateway Trust	589	0	For
Harbor ETF Trust	557	0	For
Pacer Funds Trust	506	0	For
Calamos	378	0	For
Boltwood Capital Management	375	0	For
Multi-Select Securities Fund for Puerto Rico Residents	275	0	For
Evernest Financial Advisors, LLC	200	0	For
Innovator ETFs Trust	135	0	For

31. Allocation of Dividends

CAPITAL STRUCTURE

100% fund support · no official result

FOR 99.5%

The 21 asset managers below cast 100% of the shares they voted on this item FOR (9,295,507 for, 0 against).

FOR: 9,295,507 (99.6%)ABSTAIN: 37,668 (0.4%)

Largest asset managers voting on “Allocation of Dividends” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
Charles Schwab	2,986,928	0	For
Vanguard	2,575,662	0	For
Hartford	1,695,060	0	For
SEI	781,674	0	For
Mercer Funds	450,846	0	For
Prudential/PGIM	244,597	0	For
Russell Investments	148,722	0	For
BRANDES INVESTMENT TRUST	98,429	0	For
Federated Hermes	78,906	0	For
Neuberger Berman	78,285	0	For
Global X	51,154	0	For
Brighthouse	6,097	37,668	Abstain
Morgan Stanley	33,470	0	For
IMPAX FUNDS SERIES TRUST III	21,018	0	For
PACE SELECT ADVISORS TRUST	19,907	0	For
Brown Capital Management Mutual Funds	9,811	0	For
2023 ETF Series Trust	9,652	0	For
Putnam	3,250	0	For
Adviser Managed Trust	1,336	0	For
Principal	380	0	For
Northern Lights Fund Trust IV	323	0	For

32. Amendments to Articles

CORPORATE GOVERNANCE

100% fund support · no official result

FOR 99.5%

The 21 asset managers below cast 100% of the shares they voted on this item FOR (9,295,507 for, 0 against).

FOR: 9,295,507 (99.6%)ABSTAIN: 37,668 (0.4%)

Largest asset managers voting on “Amendments to Articles” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
Charles Schwab	2,986,928	0	For
Vanguard	2,575,662	0	For
Hartford	1,695,060	0	For
SEI	781,674	0	For
Mercer Funds	450,846	0	For
Prudential/PGIM	244,597	0	For
Russell Investments	148,722	0	For
BRANDES INVESTMENT TRUST	98,429	0	For
Federated Hermes	78,906	0	For
Neuberger Berman	78,285	0	For
Global X	51,154	0	For
Brighthouse	6,097	37,668	Abstain
Morgan Stanley	33,470	0	For
IMPAX FUNDS SERIES TRUST III	21,018	0	For
PACE SELECT ADVISORS TRUST	19,907	0	For
Brown Capital Management Mutual Funds	9,811	0	For
2023 ETF Series Trust	9,652	0	For
Putnam	3,250	0	For
Adviser Managed Trust	1,336	0	For
Principal	380	0	For
Northern Lights Fund Trust IV	323	0	For

33. Appointment of Auditor; Appointment of Auditor for Sustainability Reporting

AUDIT-RELATED

100% fund support · no official result

FOR 99.5%

The 21 asset managers below cast 100% of the shares they voted on this item FOR (9,295,507 for, 0 against).

FOR: 9,295,507 (99.6%)ABSTAIN: 37,668 (0.4%)

Largest asset managers voting on “Appointment of Auditor; Appointment of Auditor for Sustainability Reporting” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
Charles Schwab	2,986,928	0	For
Vanguard	2,575,662	0	For
Hartford	1,695,060	0	For
SEI	781,674	0	For
Mercer Funds	450,846	0	For
Prudential/PGIM	244,597	0	For
Russell Investments	148,722	0	For
BRANDES INVESTMENT TRUST	98,429	0	For
Federated Hermes	78,906	0	For
Neuberger Berman	78,285	0	For
Global X	51,154	0	For
Brighthouse	6,097	37,668	Abstain
Morgan Stanley	33,470	0	For
IMPAX FUNDS SERIES TRUST III	21,018	0	For
PACE SELECT ADVISORS TRUST	19,907	0	For
Brown Capital Management Mutual Funds	9,811	0	For
2023 ETF Series Trust	9,652	0	For
Putnam	3,250	0	For
Adviser Managed Trust	1,336	0	For
Principal	380	0	For
Northern Lights Fund Trust IV	323	0	For

34. Elect Aicha Evans

DIRECTOR ELECTIONS

100% fund support · no official result

FOR 99.5%

The 21 asset managers below cast 100% of the shares they voted on this item FOR (9,295,507 for, 0 against).

FOR: 9,295,507 (99.6%)ABSTAIN: 37,668 (0.4%)

Largest asset managers voting on “Elect Aicha Evans” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
Charles Schwab	2,986,928	0	For
Vanguard	2,575,662	0	For
Hartford	1,695,060	0	For
SEI	781,674	0	For
Mercer Funds	450,846	0	For
Prudential/PGIM	244,597	0	For
Russell Investments	148,722	0	For
BRANDES INVESTMENT TRUST	98,429	0	For
Federated Hermes	78,906	0	For
Neuberger Berman	78,285	0	For
Global X	51,154	0	For
Brighthouse	6,097	37,668	Abstain
Morgan Stanley	33,470	0	For
IMPAX FUNDS SERIES TRUST III	21,018	0	For
PACE SELECT ADVISORS TRUST	19,907	0	For
Brown Capital Management Mutual Funds	9,811	0	For
2023 ETF Series Trust	9,652	0	For
Putnam	3,250	0	For
Adviser Managed Trust	1,336	0	For
Principal	380	0	For
Northern Lights Fund Trust IV	323	0	For

35. Elect Friederike Rotsch

DIRECTOR ELECTIONS

100% fund support · no official result

FOR 99.5%

The 21 asset managers below cast 100% of the shares they voted on this item FOR (9,295,507 for, 0 against).

FOR: 9,295,507 (99.6%)ABSTAIN: 37,668 (0.4%)

Largest asset managers voting on “Elect Friederike Rotsch” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
Charles Schwab	2,986,928	0	For
Vanguard	2,575,662	0	For
Hartford	1,695,060	0	For
SEI	781,674	0	For
Mercer Funds	450,846	0	For
Prudential/PGIM	244,597	0	For
Russell Investments	148,722	0	For
BRANDES INVESTMENT TRUST	98,429	0	For
Federated Hermes	78,906	0	For
Neuberger Berman	78,285	0	For
Global X	51,154	0	For
Brighthouse	6,097	37,668	Abstain
Morgan Stanley	33,470	0	For
IMPAX FUNDS SERIES TRUST III	21,018	0	For
PACE SELECT ADVISORS TRUST	19,907	0	For
Brown Capital Management Mutual Funds	9,811	0	For
2023 ETF Series Trust	9,652	0	For
Putnam	3,250	0	For
Adviser Managed Trust	1,336	0	For
Principal	380	0	For
Northern Lights Fund Trust IV	323	0	For

36. Elect Gerhard Oswald

DIRECTOR ELECTIONS

99% fund support · no official result

FOR 98%

The 21 asset managers below cast 99% of the shares they voted on this item FOR (9,158,617 for, 136,890 against).

FOR: 9,158,617 (98.1%)AGAINST: 136,890 (1.5%)ABSTAIN: 37,668 (0.4%)

Largest asset managers voting on “Elect Gerhard Oswald” at SAP SE, 2023-2024
Asset manager	For	Against	Abstain	Vote
Charles Schwab	2,986,928	0	0	For
Vanguard	2,575,662	0	0	For
Hartford	1,695,060	0	0	For
SEI	781,674	0	0	For
Mercer Funds	313,956	136,890	0	For
Prudential/PGIM	244,597	0	0	For
Russell Investments	148,722	0	0	For
BRANDES INVESTMENT TRUST	98,429	0	0	For
Federated Hermes	78,906	0	0	For
Neuberger Berman	78,285	0	0	For
Global X	51,154	0	0	For
Brighthouse	6,097	0	37,668	Abstain
Morgan Stanley	33,470	0	0	For
IMPAX FUNDS SERIES TRUST III	21,018	0	0	For
PACE SELECT ADVISORS TRUST	19,907	0	0	For
Brown Capital Management Mutual Funds	9,811	0	0	For
2023 ETF Series Trust	9,652	0	0	For
Putnam	3,250	0	0	For
Adviser Managed Trust	1,336	0	0	For
Principal	380	0	0	For
Northern Lights Fund Trust IV	323	0	0	For

37. Elect Pekka Ala-Pietila

DIRECTOR ELECTIONS

Combines 2 wordings of this item as funds reported it.

100% fund support · no official result

FOR 99.5%

The 21 asset managers below cast 100% of the shares they voted on this item FOR (9,295,507 for, 0 against).

FOR: 9,295,507 (99.6%)ABSTAIN: 37,668 (0.4%)

Largest asset managers voting on “Elect Pekka Ala-Pietila” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
Charles Schwab	2,986,928	0	For
Vanguard	2,575,662	0	For
Hartford	1,695,060	0	For
SEI	781,674	0	For
Mercer Funds	450,846	0	For
Prudential/PGIM	244,597	0	For
Russell Investments	148,722	0	For
BRANDES INVESTMENT TRUST	98,429	0	For
Federated Hermes	78,906	0	For
Neuberger Berman	78,285	0	For
Global X	51,154	0	For
Brighthouse	6,097	37,668	Abstain
Morgan Stanley	33,470	0	For
IMPAX FUNDS SERIES TRUST III	21,018	0	For
PACE SELECT ADVISORS TRUST	19,907	0	For
Brown Capital Management Mutual Funds	9,811	0	For
2023 ETF Series Trust	9,652	0	For
Putnam	3,250	0	For
Adviser Managed Trust	1,336	0	For
Principal	380	0	For
Northern Lights Fund Trust IV	323	0	For

38. Elect Ralf Herbrich

DIRECTOR ELECTIONS

100% fund support · no official result

FOR 99.5%

The 21 asset managers below cast 100% of the shares they voted on this item FOR (9,295,507 for, 0 against).

FOR: 9,295,507 (99.6%)ABSTAIN: 37,668 (0.4%)

Largest asset managers voting on “Elect Ralf Herbrich” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
Charles Schwab	2,986,928	0	For
Vanguard	2,575,662	0	For
Hartford	1,695,060	0	For
SEI	781,674	0	For
Mercer Funds	450,846	0	For
Prudential/PGIM	244,597	0	For
Russell Investments	148,722	0	For
BRANDES INVESTMENT TRUST	98,429	0	For
Federated Hermes	78,906	0	For
Neuberger Berman	78,285	0	For
Global X	51,154	0	For
Brighthouse	6,097	37,668	Abstain
Morgan Stanley	33,470	0	For
IMPAX FUNDS SERIES TRUST III	21,018	0	For
PACE SELECT ADVISORS TRUST	19,907	0	For
Brown Capital Management Mutual Funds	9,811	0	For
2023 ETF Series Trust	9,652	0	For
Putnam	3,250	0	For
Adviser Managed Trust	1,336	0	For
Principal	380	0	For
Northern Lights Fund Trust IV	323	0	For

39. Ratification of Management Board Acts

CORPORATE GOVERNANCE

100% fund support · no official result

FOR 99.5%

The 21 asset managers below cast 100% of the shares they voted on this item FOR (9,295,507 for, 0 against).

FOR: 9,295,507 (99.6%)ABSTAIN: 37,668 (0.4%)

Largest asset managers voting on “Ratification of Management Board Acts” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
Charles Schwab	2,986,928	0	For
Vanguard	2,575,662	0	For
Hartford	1,695,060	0	For
SEI	781,674	0	For
Mercer Funds	450,846	0	For
Prudential/PGIM	244,597	0	For
Russell Investments	148,722	0	For
BRANDES INVESTMENT TRUST	98,429	0	For
Federated Hermes	78,906	0	For
Neuberger Berman	78,285	0	For
Global X	51,154	0	For
Brighthouse	6,097	37,668	Abstain
Morgan Stanley	33,470	0	For
IMPAX FUNDS SERIES TRUST III	21,018	0	For
PACE SELECT ADVISORS TRUST	19,907	0	For
Brown Capital Management Mutual Funds	9,811	0	For
2023 ETF Series Trust	9,652	0	For
Putnam	3,250	0	For
Adviser Managed Trust	1,336	0	For
Principal	380	0	For
Northern Lights Fund Trust IV	323	0	For

40. Ratification of Supervisory Board Acts

CORPORATE GOVERNANCE

100% fund support · no official result

FOR 99.5%

The 21 asset managers below cast 100% of the shares they voted on this item FOR (9,295,507 for, 0 against).

FOR: 9,295,507 (99.6%)ABSTAIN: 37,668 (0.4%)

Largest asset managers voting on “Ratification of Supervisory Board Acts” at SAP SE, 2023-2024
Asset manager	For	Abstain	Vote
Charles Schwab	2,986,928	0	For
Vanguard	2,575,662	0	For
Hartford	1,695,060	0	For
SEI	781,674	0	For
Mercer Funds	450,846	0	For
Prudential/PGIM	244,597	0	For
Russell Investments	148,722	0	For
BRANDES INVESTMENT TRUST	98,429	0	For
Federated Hermes	78,906	0	For
Neuberger Berman	78,285	0	For
Global X	51,154	0	For
Brighthouse	6,097	37,668	Abstain
Morgan Stanley	33,470	0	For
IMPAX FUNDS SERIES TRUST III	21,018	0	For
PACE SELECT ADVISORS TRUST	19,907	0	For
Brown Capital Management Mutual Funds	9,811	0	For
2023 ETF Series Trust	9,652	0	For
Putnam	3,250	0	For
Adviser Managed Trust	1,336	0	For
Principal	380	0	For
Northern Lights Fund Trust IV	323	0	For

Showing the 40 reported items with the widest manager coverage, of 57 in total. View every item.

Largest SAP SE shareholders voting in 2023-2024

Ranked by the number of SAP SE shares each manager voted on the most widely held ballot item of the 2023-2024 meeting, shown as a share of the 1,228,504,232 shares outstanding at the time of that meeting.

Top SAP SE shareholders by shares voted, 2023-2024
#	Asset manager	% of shares outstanding
1	HARDING LOEVNER LP	0.35%
2	EAGLE CAPITAL MANAGEMENT LLC	0.25%
3	HARDING LOEVNER FUNDS INC	0.14%
4	Fiera Capital Corp	0.11%
5	Northern Trust	0.09%
6	ENVESTNET ASSET MANAGEMENT INC	0.07%
7	RAYMOND JAMES & ASSOCIATES	0.05%
8	Natixis	0.03%
9	MAR VISTA INVESTMENT PARTNERS LLC	0.02%
10	2023 ETF Series Trust	0.02%

Percentages above are of 1,228,504,232 shares outstanding, as reported by SAP SE on its Form 20-F dated 2023-12-31 (see the filing on EDGAR). This is the count contemporaneous with the 2023-2024 meeting, so the percentages are the ones that were true then, not ones restated against today’s share count.

About this page

Every figure above is derived from filings made with the US Securities and Exchange Commission: Form N-PX, in which registered investment companies and institutional managers disclose how they voted every proxy, and Form 8-K Item 5.07, in which the company reports its own meeting results. Shares outstanding are taken from SAP SE’s 20-F dated 2023-12-31. This page is a static snapshot rebuilt weekly on 02 October 2026; a live search always shows the current data.

At SAP SE's shareholder meeting held 2024-05-15, in the 2023-2024 proxy season, 513 asset managers reported how they voted in their SEC Form N-PX filings, covering 9,026 separate fund positions. Their filings are grouped here into 57 reported items; because filers word the same ballot item differently, that can be more than the number of items on the ballot. No official Form 8-K vote tally has been matched to this meeting, so this page states no certified outcome for its most widely held ballot item. On that item — Resolution on the approval of the compensation report for fiscal year 2023 — the reporting funds cast 99.6% of the shares they voted in favour (FOR divided by FOR plus AGAINST, the conventional basis for proxy support; abstentions, broker non-votes and unvoted shares are excluded because none of them took a side). That is the aggregate of those managers' own N-PX disclosures, not the company's certified result, and the funds are a subset of all shareholders.

SAP SE proxy season coverage: 2023-2024 (this page) · 2024-2025 · 2025-2026.