Standards of Business Conduct

At Microsoft, we know that how we conduct ourselves and our business is as important as delivering outstanding products and services. The way we work with customers, partners, governments, vendors, and communities worldwide is fundamental to our success as a company.

Microsoft is committed to responsible business practices. They are part of our core values and our daily work. That means being open about our business operations, transparent in all of our dealings with stakeholders, and compliant with the laws and regulations that apply to our business. It also means having the honesty to acknowledge when we fall short of those goals, and having the integrity to set things right. We strive to exceed legal requirements by conducting our business responsibly and with integrity.

The Microsoft Standards of Business Conduct summarizes the regulatory requirements and business practices that guide our decision making and business activities. Every Microsoft employee is required to take a course on these standards and to sign a statement that indicates a personal intention to adhere to the collective commitment of ethical business behavior, and to legal and regulatory compliance.

Standards of Business Conduct

Microsoft Office of Legal Compliance

The Office of Legal Compliance (OLC) supervises and oversees the establishment, implementation, and maintenance of effective and collaborative compliance and governance programs. As part of this, the OLC distributes a "newspaper of record" that covers corporate policy and training announcements. This is sent to every full-time Microsoft employee around the world.

Worldwide Compliance Network

To facilitate the Microsoft Business Conduct and Compliance program, the OLC partnered with the Sales, Marketing, and Services Group (SMSG) Finance organization to further define a multidisciplinary, global compliance committee structure and processes.

The structure includes a worldwide SMSG committee that is responsible for overseeing the regional compliance committees, such as those in Latin America (Latam), North America, Asia Pacific (APAC), Japan, and Europe, Middle East, and Africa (EMEA). There are also local compliance committees in select geographies. The committees are made up of representatives from Human Resources, Legal and Corporate Affairs, Finance, and SMSG Finance.

The compliance committees are charged with working with the Office of Legal Compliance to:

• Increase global awareness of the compliance program.
• Assist in the development and implementation of legal and compliance education programs and initiatives.
• Ensure employee awareness of changes to corporate policy.
• Provide oversight for regional investigative matters.
• Collaborate with the Office of Legal Compliance on its ongoing risk-assessment obligations.

Reporting Concerns

Employees, partners, customers, or others outside the company who have concerns about compliance or Microsoft business practices can report their concerns to the Office of Legal Compliance.