Microsoft's State Owned Entity Criteria

  • The Entity is Government Controlled, as indicated by:
    • 30% or greater government ownership.
    • Government voting or board appointment control.
    • Government’s formal designation of the entity as a government agency or SOE.
    • Financing through government appropriations, tax revenue, licenses, fees, or royalties.
    • Payment of profits to the government.
    • Funding of entity by the government in the event it fails to "break even".
  • The Entity Performs a Government Function, as indicated by:
    • Providing services to the public at large. For example:
      • Medical services
      • Public educational services
      • Public transportation
      • Banking or financial services
      • Utility services (e.g., telecommunications, gas, electric, water, sewage)
      • Media (e.g., broadcast, print)
      • Energy exploration and development
      • Other goods or services that are in the public’s interest
    • A perception or understanding by the public or government of the host country that the entity performs a government function.
    • Employees of the entity are considered to be public officials or civil servants.
    • Exercising a monopoly over the services provided.
    • Receiving government subsidies to offset costs associated with the services provided.
  • Additional SOE Consideration Criteria to Consider When Evaluating the Factors Above:
    • Based on geography, the entity is highly likely to be state owned or controlled (e.g., China).
    • The length of time each of the applicable factors above have existed.

Download the Anti-Corruption Policy for Representatives