We prohibit corruption and bribery

We prohibit corrupt payments of all kinds, including facilitating payments. We expect our representatives to share our commitment to integrity, and if we see signs that a representative is unethical or could be engaging in corrupt conduct, we prohibit doing business with them.

Our anti-corruption standard and policy

Our standard

We prohibit offering or paying bribes, kickbacks, or other improper benefits to anyone. We will forego business rather than secure it through a bribe, kickback, or other improper benefit.

Our policy

We prohibit improperly giving, promising, offering, or authorizing payment of anything of value in order to obtain or keep business or to secure some other advantage for Microsoft.

Investigations

We offer multiple ways for employees or third parties to report potential compliance concerns, including anonymously through an external hotline provider. We maintain a comprehensive, global compliance investigation team to review and, if necessary, investigate reported concerns. If the investigation uncovers violations of policy or law, the company takes appropriate remedial action, including discipline of employees and sanctions or removal of partners or vendors. The investigations team reports on data and trends and educates employees through case studies.

Reporting concerns

We offer multiple ways for employees or third parties to report potential compliance concerns, including anonymously through an external hotline provider. We maintain a comprehensive, global compliance investigation team to review and investigate reported compliance concerns. If the investigation uncovers violations of policy or law, the company takes appropriate remedial action, which may include discipline of employees, enhanced controls, and removal of partners or vendors. The investigations team reports on data and trends, and we train our employees using lessons learned from our investigations.

Download and read our Anti-Corruption Policy

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Our training courses

Compliance Analytics Program

We are using compliance professionals and digital technologies to detect and mitigate corruption risks and are working hard to expand these efforts to cover additional enterprise risk areas. Our analytics program focuses on flagging high risk deals and partners and prioritizing risk mitigation efforts so that our compliance professionals and investigators can apply additional oversight. To accomplish this, we rely on cloud-based data analytic solutions that use statistics, machine learning, and artificial intelligence to unearth trends, patterns, relationships, and anomalies. These insights are shared throughout the compliance community, and with senior leadership to improve our overall risk management practices and policies. Collectively, this community of data scientists, analysts, and domain experts comprises the company’s Compliance Analytics Program. Learn how we monitor sales transactions.

More about our program

Managing third parties

We require our partners, suppliers, and other representatives to comply with the Anti-Corruption Policy for Microsoft Representatives. We conduct risk-based due diligence and vetting of our representatives. The vetting process now uses data analytics to identify higher risk representatives through an algorithm that calculates a risk score for representatives based on internal and external data attributes. We began using these data analytics in 2019 to conduct due diligence on some representatives and continue to work on expanding this unique program. We require that higher risk representatives undergo enhanced vetting allowing us to determine whether they will be permitted to start or renew a business relationship with us. Our partner compliance analytics also provide real-time insights, allowing Microsoft to make more informed compliance and business decisions.

Risk assessment

Our corruption and bribery risk assessments help drive our decisions and priorities for enhancing controls, processes, and monitoring. Our vetting and transaction monitoring programs are based on sophisticated risk analytics.

ISO 37001 certification

We’ve taken steps to ensure that our compliance program meets the highest standards for such programs, including ISO 37001, the new Anti-Bribery Management System Standard. Independent and accredited certification bodies have reviewed our implementations of ISO 37001 to date, based on all the work that we’ve done in the last few years, and have certified that the subsidiaries and global business group reviewed meet ISO 37001 requirements.