Microsoft’s Compliance Program

Administration & Enforcement

The Standards and Microsoft’s Business Conduct and Compliance Program (the “Program”) are endorsed by and have the full support of the Board of Directors. The Board of Directors and management are responsible for overseeing compliance with and enforcing the Standards.

The General Counsel serves as the company’s Chief Compliance Officer and has overall responsibility for the management of the Program. The General Counsel reports directly to the CEO and, for this purpose, to the Audit Committee of the Board of Directors. The General Counsel, through the Deputy General Counsel and Vice President for the Office of the General Counsel, oversees the Office of Legal Compliance (OLC).

The OLC, among other things, applies and interprets the Standards, manages the intake and investigation of compliance concerns, disseminates ethics and compliance trainings and communications, and assists with the design and implementation of preventive compliance measures. The OLC is managed by the Director of Compliance who reports to the Deputy General Counsel and Vice President for the Office of the General Counsel. The Deputy General Counsel and Director of Compliance have direct access and reporting obligations to the Audit Committee of the Board of Directors. In administering the Program, the OLC works closely with the rest of Corporate, External, and Legal Affairs, Finance, Human Resources, Internal Audit, and other groups focused on ensuring compliance.

Serious Consequences for Not Following the Standards

Violations of the Standards are not tolerated.

Consequences for violations may include disciplinary action, up to and including termination of employment, and possible civil or criminal liability. Individuals who have willfully failed to report known violations by others may also be subject to disciplinary action.

Any employee who makes a knowingly false report of a possible violation for the purpose of harming another individual may be subject to disciplinary action.

Awards & Recognition

Being recognized as a quality global workplace is an honor for Microsoft.  Our investments in our employees, the opportunities we create for our employees, and safeguarding the Company have not gone unnoticed.  We are particularly proud of the work our people achieve every day, and the impact that we have on the world around us.