Microsoft’s Commitment to Anti-Corruption

100 Best Corporate Citizens

Our Commitment to Anti-Corruption
& Anti-Bribery

Microsoft prohibits corruption of government officials and the payment of bribes or kickbacks of any kind, whether in dealings with public officials or individuals in the private sector.

Corruption promotes poverty, hunger, disease, and crime, and keeps societies and individuals from reaching their full potential.  Corruption is one of the leading obstacles to economic and social development.  It distorts the rule of law and the institutional foundation on which Microsoft depends.  Microsoft is committed to observing the standards of conduct set forth in the United States Foreign Corrupt Practices Act and the applicable Anti-Corruption and Anti-Money laundering laws of the countries in which we operate.

Overview of Microsoft’s Standards of Business Conduct

As responsible business leaders, it is not enough to intend to do things right, we must also do them in the right way. That means making business decisions and taking appropriate actions that are ethical and in compliance with applicable legal requirements. The Microsoft Standards of Business Conduct summarizes the regulatory requirements and business practices that guide our decision making and business activities. The Standards contain basic information about our policies as well as information about how to obtain guidance regarding a particular business practice or compliance concern.

Microsoft policy and practice encourage the use of good judgment, discretion, and moderation when giving or accepting gifts or entertainment in business settings. Gift giving and entertainment practices may vary in different cultures, however, any gifts and entertainment given or received must be in compliance with law, must not violate the giver’s and/or receiver’s policies on the matter, and be consistent with local custom and practice. We do not solicit gifts, entertainment, or favors of any value from persons or firms with which Microsoft actually or potentially does business. Nor do we act in a manner that would place any vendor or customer in a position where he/she may feel obligated to make a gift, provide entertainment, or provide personal favors in order to do business or continue to do business with Microsoft.

Download the Anti-Corruption Policy for Representatives

Download the Anti-Corruption Training for Microsoft Partners

Working with Trustworthy Representatives

Microsoft Corporation, and all of its subsidiaries and joint ventures worldwide ("Microsoft"), requires its channel partners (for example, resellers, software advisors, original equipment manufacturers, and distributors), suppliers, vendors, consultants, lobbyists, and any other third-party representative (collectively, "Microsoft Representatives") to comply with this Policy.

Microsoft prohibits corruption of government officials and the payments of bribes or kickbacks of any kind, whether in dealings with public officials or individuals in the private sector.

Microsoft is committed to observing the standards of conduct set forth in the United States Foreign Corrupt Practices Act ("FCPA") and the applicable Anti-Corruption and anti-money laundering laws of the countries in which we operate.

Partners are responsible for training all employees who work on behalf of Microsoft. We provide online training free of charge and other resources in the materials to the left.

Microsoft’s Supplier Code of Conduct

Through the Standards of Business Conduct, Microsoft has established company standards that include ethical business practices and regulatory compliance.  These standards apply to all Microsoft employees, directors, and officers.  Similarly, Microsoft expects its suppliers to embrace this commitment to integrity by complying with and training its employees on the Microsoft Supplier Code of Conduct .

Suppliers and their employees, agents, and subcontractors (collectively referred to as "Suppliers") must adhere to this Supplier Code of Conduct Policy while conducting business with or on behalf of Microsoft (The terms "vendor" and "supplier" are used interchangeably).  Suppliers must promptly inform their Microsoft contact (or a member of Microsoft management) when any situation develops that causes the Supplier to operate in violation of this Code of Conduct Policy.  While Microsoft Suppliers are expected to self-monitor and demonstrate their compliance with this Code of Conduct, Microsoft may audit Suppliers or inspect Suppliers’ facilities to confirm compliance.  Microsoft may require the immediate removal of any Supplier representative(s) or personnel who behave in a manner that is unlawful or inconsistent with this Code of Conduct or any Microsoft policy.  Compliance with this Code of Conduct, and attending training on this Code of Conduct, as may be offered by Microsoft, is required in addition to any other obligations in any agreement a Supplier may have with Microsoft.

Representative Vetting and Contracting

Microsoft performs regular monitoring of its Anti-Corruption program through various methods, one of which is risk-based due diligence ("vetting") of Representatives.  Microsoft requires that certain Representatives be subject to enhanced vetting before they are permitted to start or renew a business relationship with our Company, or any subsidiaries.

Contracts between Microsoft and Representatives generally include mandatory Anti-Corruption clauses.

Download the Supplier Code of Conduct