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 end our business relationship with them.

Our Anti-Corruption Compliance Program

As a company, we do not and will not tolerate violations of our standards and policies. Our anti-corruption compliance program is designed to prevent, detect, and fix compliance issues. We approach compliance with a growth mindset and a process of continuous improvement, and we invest heavily in innovative and fresh approaches.

We communicate our values through our conduct and in email, leadership videos, training, and content that leaders at Microsoft use to reinforce the importance of building and maintaining trust with our customers, governments, representatives, and each other.

Standards of Business Conduct Course

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Microsoft’s Anti-Corruption 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.

Microsoft’s Anti-Corruption 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.

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Anti-corruption 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 compliance anti-corruption 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.

Compliance Analytics Program

We are using digital technologies to create an early warning and monitoring system for corruption risks. We continue to work on expanding this program to cover additional risk regions and sales programs. Our goal is to identify and review sales transactions and third parties that create the highest corruption risk, and provide additional oversight of these transactions and representatives. To accomplish this goal, we have invested in on-premise and cloud-based data analytic solutions that use advanced statistics, machine learning, and artificial intelligence. These solutions allow us to “risk score” transactions and representatives to identify trends, patterns, relationships, and anomalies. These insights trigger compliance reviews conducted by compliance and finance teams. These end-to-end solutions combine to form the Compliance Analytics 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.