"Microsoft is committed to principled, accountable, and transparent business practices
that meet our responsibilities as a global company."
– Brad Smith, General Counsel
Each day we interact with a variety of individuals and groups - including our customers,
partners, competitors, co-workers, shareholders, vendors, government and regulatory
agencies, and the communities in which we operate. We are committed to interacting
with all of these audiences in a respectful, ethical manner and in compliance with
applicable laws and regulatory requirements. We train employees annually in our
Standards of Business Conduct and have strong
compliance systems to ensure the principles are upheld and take corrective
action if they are not. We have a sophisticated set of
Political Engagement policies to ensure that our participation in the policy
process is transparent and maintains appropriate and strong anti-bribery and anti-corruption
policies and systems. To learn more about Microsoft’s Commitment to Anti-Corruption,
please visit the Anti-Corruption and Anti-Bribery. Additionally, you can
download the current
Anti-Corruption Policy for Representatives.
We also have a strong set of industry-leading
corporate governance policies and systems in place designed to:
- Establish and preserve management accountability to Microsoft's owners by appropriately
distributing rights and responsibilities among Microsoft Board members, managers,
- Provide a structure through which management and the Board set objectives and monitor
- Strengthen and safeguard our culture of business integrity and responsible business
- Encourage the efficient use of resources, and to require
accountability for stewardship of those resources.
In working to conduct our business with integrity, we engage with a wide range of
stakeholders across all parts of our business operations. We also benefit from participating
in a range of groups and initiatives addressing corporate responsibility including
the United Nations Global
Compact, Business for Social Responsibility,
the Boston College Center for
Corporate Citizenship, and the
World Economic Forum's Partnering Against Corruption Initiative.
As a US-based company, we comply with, or exceed, governance codes used in the United
Microsoft Office of Legal Compliance
The Office of Legal Compliance (OLC) supervises 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
include 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
- Increase global awareness of the compliance program.
- Help develop and implement 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.
Employees, partners, customers, or others outside the company who have concerns
about compliance or Microsoft business practices can report their concerns to the
Microsoft Integrity Hotline.