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Trust with Investors & the Public

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

Don’t Trade on Inside Information

We maintain trust with our investors and the public by respecting financial laws, which means we do not trade based on 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 that 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.

How we build trust:

  • We never buy or sell any securities based on material, nonpublic information.
  • We do not give someone else (for example, a friend, spouse, or broker) a “tip” regarding material, non-public information.
  • We do not recommend or suggest that anyone else trade in the securities of any company based on material nonpublic information, even if we are not sharing the information itself.
  • We consult with CELA before buying or selling public securities where we have questions as to whether we may be in possession of material nonpublic information.

Learn More:

Insider Trading Policy
Restricted Trading Window Policy

Keep Accurate Records & 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.

How we build trust:

  • 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
Custom & Side Agreements Policy
Document Retention Policy

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.

How we build trust:

  • 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
Social Media Guidelines
Public Advocacy Policy

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.

How we build trust:

  • We spend Microsoft’s funds wisely, and guard against waste and abuse.
  • We exercise good judgment when using company-provided technology resources, and use them for personal reasons only if it does not interfere with our job responsibilities or harm our work environment.
  • We use our corporate accounts and services, not personal accounts or services, for business correspondence and data.
  • We understand that business-related data is Microsoft’s property, and that it may be accessed, preserved, and reviewed in accordance with our polices and applicable laws.

Learn More:

Responsible Use of Technology Policy
Expense Policy

Protect Confidential Information & 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 we build trust:

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

Learn More:

Confidential Information Policy
Copyright Policy