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Trust Code: Microsoft Standards of Business Conduct

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Trust with customers Trust with governments and communities Trust with each other Trust with our investors and the public Trust with our representatives

Trust with our customers

Our ability to meet people and organizations where they are, with what they want and need, is our path to success. Our customers must be at the center of everything we do. Look for ways to engage our customers, advocate for them, and empower them to achieve more.

Two men working at a profit-for-purpose company in South Africa having a discussion.

When making decisions, ask yourself: does this build or harm trust with our customers?

Nelson Palmer from the SBC training video working at a computer in a darkened office, with a screen behind him displaying computer code.

Honor privacy

We honor privacy by being transparent about how we handle customer data, including personal data. We want our customers to trust us to protect their privacy and use their data in the ways that they permit us.

Mobile professional using a Surface Book and Surface Pen viewing a financial chart.

Don’t make improper payments

We are committed to truthful and transparent interactions with customers, and we prohibit any attempt to influence their decisions through improper payments. Corruption can harm our customers in many ways, including sometimes causing them to pay more than they should. Winning and preserving customers’ trust every day is more important than any benefit we might get from doing business improperly. In some parts of the world, paying bribes to get business may be something that others do. We prohibit them. We would rather lose the business than secure it through a bribe, kickback, or other improper benefit.

Five characters from the SBC training video at a table in a bar having a conversation.

Compete fairly

The way we compete is as important as the result we achieve. Healthy competition and fair business practices put our customers first by giving them access to a variety of products and services at fair prices. Competing fairly ensures that we meet our business objectives with our integrity intact.

How to build trust:

By following local privacy and data protection laws.
By providing clear and accurate privacy notices when collecting or processing personal data, including employee personal data.
By honoring privacy choices by using customer data to provide the services customers have agreed to.
By protecting our customers’ data through building secure products and services.

Learn more

Privacy principles

By refusing to offer or pay bribes or kickbacks to anyone.
By prohibiting corrupt payments of all kinds, including payments to secure permits or approvals, and small payments to speed up a routine government process (often known as a “facilitating payment”).
In any deal, we will avoid hidden terms or arrangements and reduce complexity wherever possible, because transparent transactions reduce the risk of a bribe or kickback.
By using partners that have a reputation for integrity, and reporting signs that a representative is unethical or could be paying a bribe.
By making sure that any gifts, hospitality, or travel we offer to government officials or customers are reasonable and appropriate, and pre-approved where necessary.
By hiring candidates based on their merits, and not make hiring decisions to benefit a customer or government official.
If we make charitable donations, we will do so to support a legitimate charitable cause, not as part of an exchange of favors.

Learn more

Anti-Corruption Policy

Giving Gifts, Hospitality & Travel to Government Officials (internal only)

Commitment to anti-corruption and anti-bribery

By avoiding any formal or informal agreements with competitors that limit competition.
By respecting competitive bidding processes, and not rigging or fixing the outcomes or helping anyone else do so.
By not dictating the prices that our independent channel partners charge their customers.
By gathering competitive intelligence using only appropriate resources, being truthful, and not misrepresenting who we are.

Learn more

Competitive Intelligence Policy (internal only)

Microsoft Fair Competition Policy (internal only)

Trust with government and communities

Achieving our mission depends on governments and communities knowing that we will follow the laws and customs of the countries where we operate, and respect human rights across the globe.

Two female politicians talking in a government building.

When making decisions, ask yourself: does this foster trust with governments and communities?

A medical worker goes through paperwork, including height measurement graphs, as part of a nutrition enhancement program in Madagascar.

Respect laws around the world

We operate around the globe and commit to respecting the laws wherever we do business. This helps us to build trust with governments, strengthen the communities where we live and work, and contribute to a fair society where we enjoy the protection of these same laws.

A man who is blind, types on a braille keyboard while also working through a mobile phone.

Design accessible products and services

We prioritize inclusive design in the development of our products and services. With over one billion people around the world with disabilities, we have an opportunity and a responsibility to design inclusively. Investing in accessibility helps Microsoft support our customers to meet inclusion goals. We believe there are no limits to what people can achieve when technology reflects the diversity of everyone who uses it.

Two farm workers during wheat harvest in a field near Delhi—one is smiling and looking at camera.

Respect and promote human rights

We are committed to respecting and promoting human rights to empower people across the globe to use technology for the good of humanity.

Man in front of computer looking to his left side

Develop and deploy Responsible AI

We are committed to developing and deploying AI technologies in a way that is consistent with our AI principles, Responsible AI Standard, our company mission, values, and our commitment to human rights. We strive to create systems that people trust. This means keeping people and their goals at the center of system design decisions and respecting enduring values like fairness, reliability and safety, privacy and security, inclusiveness, transparency, and accountability.

How to build trust:

By following the laws and regulations of the U.S. and of all the places where we operate.
By being honest and transparent in our discussions with government representatives and officials.
By responding truthfully, appropriately, and promptly to government inquiries requests for information.
By respecting and complying with global trade controls and economic sanctions that prohibit us from doing business with certain countries, governments, entities, and individuals.
By observing and complying with laws that govern how our technology may be distributed and used internationally.

Learn more

Worldwide Trade Compliance Policy (internal only)

TradeNet (internal only)

By including and learning from people with a range of perspectives, designing inclusively and putting people in the center from the very start of the design process.
By making our products accessible to all users, including users with vision, hearing, learning, mobility, mental health, age-related, sensory, and speech disabilities.

Learn more

Accessibility Portal (internal only)

Accessibility Academy (internal only)

Accessibility Policy (internal only)

We believe that in the long run, our presence and responsible engagement with people, governments, and other stakeholders in countries with significant human rights challenges often holds greater promise for the advancement of human rights.
We respect and advocate for the rule of law and human rights under international laws, principles, and norms.
We respect the rights to freedom of expression and privacy on all of our online services.
When we face requirements from governments to provide user data or remove content, we verify whether the government demands are valid, binding, and otherwise comply with the rule of law.
We conduct due diligence to assess the impact of our technologies on human rights. We learn from stakeholders to challenge our thinking, develop, and refine our policies and practices, and improve our technologies and how we provide them to fulfill our commitment to human rights.

Learn more

Our commitment to human rights

By following the Microsoft Responsible AI Standard when developing and deploying AI technologies.
By reporting Sensitive Uses to the Office of Responsible AI and following the guidance you receive.
By asking for help when in need of additional guidance.

Learn More web links:

Office of Responsible AI (internal)

Microsoft Responsible AI Policy (internal)

Report a Sensitive Use (internal)

Microsoft Responsible AI Principles (external)

Microsoft’s Responsible AI Standard (external)

Trust with each other

The strongest contributions come from teams who trust each other—those that can be open, honest, and constructive with one another. It takes all of us working together to cultivate an atmosphere of mutual respect, inclusion, and collaboration.

Two female tech workers collaborate in a common office space.

When making decisions, ask yourself: does this improve how we work together as One Microsoft?

Stuart Pixley, a man who uses a wheelchair, talks to a colleague in the lobby of an office building.

Foster diversity and inclusion

We work better together because of our differences, not despite them. We believe that we best serve everyone on the planet and enrich our own culture through the diverse skills, experiences, and backgrounds that each of us brings.

Two female developers working and collaborating in an enterprise office.

Contribute to a safe and productive workplace

We are committed to a work environment that empowers everyone to do their best work. A safe workplace inspires trust and allows us all to contribute and succeed. Discrimination, harassment, and unsafe working conditions diminish what we can achieve together.

Two characters from the SBC training video are at a café having a lunch conversation with a third person.

Avoid conflicts of interest

Conflicts of interest can arise when our personal relationships or financial interests overlap with our job responsibilities. If we don’t navigate potential conflicts of interest carefully, these situations can impact the decisions we make, erode trust within teams, and harm Microsoft's reputation.

How to build trust:

By providing equal employment opportunities to all qualified candidates and employees.
By not discriminating based on age, ancestry, color, family or medical care leave, gender identity or expression, genetic information, marital status, medical condition, national origin, physical or mental disability, political affiliation, protected veteran status, race, religion, sex (including pregnancy), sexual orientation, or any other characteristic protected by applicable laws, regulations, and ordinances.
By remaining committed to hiring people with disabilities and providing reasonable accommodations to qualified employees.
By examining our unconscious biases and taking steps to create an inclusive culture that makes every employee feel welcome.

Learn more

Equal Employment Opportunity Policy (internal only)

Global diversity and inclusion

By treating others with respect and not tolerating harassment or discrimination.
By integrating sound safety and health practices into our operations and complying with workplace safety regulations.
By resolving problems respectfully, and never resorting to acts or threats of violence.
By not working under the influence of drugs or alcohol.

Learn more

Anti-Harassment and Discrimination Policy (internal only)

Entertainment Policy (internal only)

Workplace Violence Policy (internal only)

Drug-free Workplace Policy (internal only)

By acting in the best interests of Microsoft.
By avoiding or withdrawing from situations where a personal relationship or financial interest in another company might influence how we make decisions in our jobs.
By understanding that a conflict of interest can exist even if we are convinced that our decisions will not be affected by the outside relationship.
When conflicts of interest arise, by disclosing them and getting advice or approval.
Before taking on outside work, ensuring that the work does not harm Microsoft’s business interests or break any employee agreements we have signed.

Learn more

Conflicts of Interest Policy (internal only)

Conflicts of Interest Approval Tool (internal only)

Outside Work Policy (internal only)

Trust with our investors and the public

Our investors must have confidence that we will create value for them in a responsible and thoughtful way. Earn their trust by protecting our assets and information, accurately stating where we are headed as a company, and honestly communicating with them and the public.

A male business professional in a large foyer is on a mobile device.

When making decisions, ask yourself: does this strengthen or harm Microsoft’s reputation with investors and the public?

John Thompson from the SBC video is leading a group of five office workers down an office hallway while they carry on a conversation.

Don’t trade on inside information

To maintain trust with our investors and the public we respect securities laws, which means we do not trade while in possession of material, nonpublic information.

In our work, we may become aware of material, nonpublic information about Microsoft or companies we do business with. Information is “material” if a reasonable investor would consider it important in deciding whether to buy or sell a company’s securities. Information is “nonpublic” if it has not been broadly communicated to the investing public.

Trading Microsoft stock or the stock of any other company based on this information not only breaks trust with our investors and the public, but is also illegal, violates company policy, and is unfair to other investors.

A large screen displaying a number of digital charts and graphs in blue and white tones.

Keep accurate records and contracts

Our records are clear, accurate, and complete. Investors rely on accurate and easily comprehensible information to understand our financial results and where we are headed as a company, and to have confidence in that direction. Keeping accurate records is critical to maintaining investors’ trust, making good business decisions, and meeting our regulatory obligations as a public company.

A female worker taking notes on a notepad.

Communicate accurately to the public

Our public statements and communications are honest and not misleading. What we say and how we say it matters. We will win and preserve the trust of our investors and the public only if they know they can rely on what we tell them.

A man wearing a hooded sweatshirt inside a secure office room pointing at a geographic area displayed on a large monitor.

Safeguard Microsoft’s resources

We are responsible stewards of Microsoft’s resources. We use company resources and money to do our jobs every day. These resources belong to Microsoft; we owe it to our investors to use them responsibly and in ways that preserve trust and add value.

Exterior view of two skyscraper towers in a city setting.

Protect confidential information and intellectual property

We protect and respect the business value of information and ideas, whether they belong to Microsoft or another company. We might lose our competitive advantage if we disclose Microsoft’s confidential information. We lose trust if we disclose confidential information, we learn from the companies we do business with. Protecting information and ideas, whether our own or those of others, is crucial to our business success and builds our reputation as a trustworthy partner.

How to build trust:

By never buying or selling any securities based on material, nonpublic information of Microsoft or acquired through our employment.
By never giving someone else (for example, a friend, spouse, or broker) a “tip” regarding material, non-public information.
By never recommending or suggesting that anyone else trade in securities based on material, nonpublic information of Microsoft or acquired through or our employment, even if we are not sharing the information itself.

Learn more

Insider Trading Policy (internal only)

Restricted Trading Window Policy (internal only)

We honestly and accurately record and report financial transactions and business information, following applicable laws, regulations, and accounting practices.
We are transparent about our commitments to our partners and customers, and our written contracts reflect the actual economics of the deal.
We don’t make side agreements or other “off-the-book” arrangements.
We use standard agreements and contracting processes or get approval for custom terms.
We execute financial transactions only with appropriate authorization and record them in compliance with Microsoft’s accounting practices.
The CEO, CFO, Corporate Controller, and other employees in the finance organization comply with the Finance Code of Professional Conduct.
When we retain and dispose of documents, we follow established corporate retention requirements that meet our legal obligations and long- term business needs.

Learn more

Finance Code of Professional Conduct (internal only)

Custom and Side Agreements (internal only)

Document Retention Policy (internal only)

We make full, accurate, and timely financial disclosures in reports and documents we submit to the U.S. Securities and Exchange Commission and in other public statements.
We listen carefully to feedback and questions from investors and other stakeholders.
We do not speak on behalf of the company unless authorized to do so; we direct analyst and media inquiries to Investor Relations or Public Relations.
We make sure that any communications about our products and services are honest and accurate.
If we endorse our products and services on social media, we make our company affiliation clear and state our honest opinion or belief about the endorsed product or service.
Our advertising and promotional material are accurate and free from false claims.

Learn more

Financial Information Disclosure Policy (internal only)

Social Media Guidelines (internal only)

Public Advocacy Policy (internal only)

By spending Microsoft’s funds wisely and guarding against waste and abuse.
By exercising good judgment when using company-provided technology resources and using them for personal reasons in accordance with company policy and only if it does not interfere with our job responsibilities or harm our work environment.
By using our corporate accounts and services, not personal accounts or services, for business correspondence and data.
By understanding that business-related data is Microsoft’s property, and that it may be accessed, preserved, and reviewed in accordance with our policies and applicable laws.

Learn more

Responsible Use of Technology Policy (internal only)

Expense Policy (internal only)

By using best practices to protect access to confidential information, and avoiding discussing it in common spaces, or with colleagues who don’t need to know it.
By not using confidential information for non-Microsoft business use and maintaining confidentiality even if we stop working for Microsoft.
By preserving Microsoft’s own intellectual property rights through copyrights, trademarks, and other forms of intellectual property that protect the value of our innovation.
By respecting the confidentiality and intellectual property rights of others, and not using use others’ confidential information without authorization.
By not using or copying third-party copyrighted materials, like software, graphics, videos, and music, without a license or permission from CELA.

Learn more

Confidential Information Policy (internal only)

Trust with our representatives

We hold ourselves to high ethical standards, and we expect our representatives, who are the partners, vendors, consultants, and other companies who work on our behalf, to meet the standards we set for ourselves. We earn trust with our representatives when we return value to them, and don’t ask them to do anything we would not do ourselves.

Two female workers having a discussion outside an office building.

When making decisions, ask yourself: will this strengthen our long-term working relationship with our representatives and customers?

Three workers having a discussion outside city hall.

Use trustworthy representatives

We strive to use honest, ethical representatives who commit to doing business ethically when working on our behalf. Our business relies on a large network of representatives—such as partners, vendors, and consultants—for success. Their actions reflect on our company’s reputation as much as our own. When our representatives do business with integrity, we retain and strengthen the trust we’ve established with our customers and the public.

A senior businessman, creative team leader, and female team member having a meeting at a restaurant.

Treat gifts, hospitality, and travel responsibly

We strive to demonstrate sound judgment and moderation when exchanging business courtesies. Giving and receiving gifts, hospitality, and travel can build strong working relationships and goodwill between Microsoft and those we do business with. But gifts, meals, or trips that are extravagant or lack transparency or a legitimate purpose may be viewed as bribes or as simply inappropriate. These things erode trust and harm our business.

Remote business professional sitting in café using a convertible laptop as a tablet.

Choose suppliers with integrity

We rely on our supplier relationships for our success. To achieve our mission, we need suppliers that are as committed as we are to building trust with our customers, that will do great work, and that will follow the law.

How to build trust:

By understanding our representatives’ qualifications and reputation before we engage them to work on our behalf.
By understanding the reasons for including a particular representative in a deal or transaction, and only do so where it’s appropriate.
By cultivating trust with our representatives and never asking or suggesting that they do things that are not allowed under the law or our policies.
By not pressuring partners or resellers to place orders for products or services they do not want or need, and by not retaliating against them if they refuse to do so.
By reporting signs that a representative could be engaging in corrupt or unethical behavior while representing Microsoft.

Learn more

Trustworthy Representative Policy (internal only)

Ethical Sales Policy (internal only)

By developing positive relationships free of corruption and commercial bribery.
When offering or accepting gifts, hospitality, or travel, by making sure they are reasonable, appropriate, and have a legitimate business purpose.
By not giving or accepting cash.
By not soliciting gifts, hospitality, or travel from third parties, or making them feel obligated to provide something in order to do business with us.
By not asking a representative, like a partner or supplier, to give gifts, hospitality, or travel on our behalf.

Learn more

Giving Gifts, Hospitality, and Travel to Government Officials Policy (internal only)

Giving Gifts, Hospitality, and Travel to Commercial Recipients Policy (internal only)

Accepting Gifts, Hospitality, and Travel Policy (internal only)

By selecting the best suppliers for the job, and by carefully considering their proven track record, reputation for integrity, and other merits—not based on favoritism.
By working to eliminate child labor, human trafficking, and other labor abuses in our supply chain.

Learn more

Supplier Contracting Policy (internal only)

Procurement Policy (internal only)

Upholding our Trust Code

Employees’ responsibilities Role of managers

Employees are expected to uphold this Trust Code, Microsoft policies, and the law. This means you must:

Read, understand, and comply

Read, understand, and comply with this Trust Code, and the policies, laws, and regulations that apply to your job.

Speak up

Speak up when we see possible violations of the Trust Code, Microsoft policies, and legal and regulatory requirements.

Be truthful

Be truthful and cooperate fully in any internal investigations. Do not conceal or destroy information.

Complete training

Complete training on the Trust Code, and attest that you understand and commit to comply with the Trust Code. Failing to read or attest to the Trust Code does not excuse you from these responsibilities.

As a leader, you have a special responsibility for setting the culture and the work environment for your team.

The way you make decisions, and handle concerns, different opinions, and even bad news, will set the foundation for trust with your teams, customers, and stakeholders. Your success and the success of your team depends on the trust you build together. Take these simple steps to build a culture of trust and integrity on your team:

Communicate

Communicate regularly the importance of ethics and integrity to your team and be clear that you expect work to be done ethically.

Model

Lead by example, by modeling ethical decision-making and good judgment.

Question

Ensure your team knows that for results to matter, they must be achieved the right way. Then, ask questions and satisfy yourself that results have been achieved the right way.

Listen

Make sure your team knows you will listen, even if they have something difficult to say.

Microsoft’s Standards of Business Conduct and its Compliance and Ethics Program are endorsed by and have the full support of Microsoft’s Board of Directors. The Board of Directors and management are responsible for overseeing the Compliance and Ethics Program and compliance with these Standards. These Standards apply to Microsoft, its Board of Directors, and all employees, directors, executive officers of Microsoft. When we refer to “Microsoft” we mean Microsoft Corporation and all its subsidiaries and affiliates in which it directly or indirectly owns more than 50% of the voting controls. References to “employees” include the Board of Directors, employees, directors, and executive officers of Microsoft. Only the Board of Directors may waive a provision of these Standards for a director or executive officer. Any waiver that is granted to a director or executive officer will be publicly disclosed as required by NASDAQ listing requirements and applicable laws, rules, and regulations. These Standards are important to us. Violation of these Standards may result in disciplinary action, up to and including termination of employment. Employees are expected to always exercise common sense and good judgment and to act responsibly, irrespective of the existence of a policy that prohibits specific behavior.