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OUR COMMITMENT TO ANTI-CORRUPTION & ANTI-BRIBERY

We prohibit offering or paying bribes, kickbacks, or other improper benefits to
anyone.


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 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.


OUR TRUST CODE

We want our employees to feel comfortable speaking up and sharing their
concerns. Our company-wide Trust Code drives awareness of the importance of
compliance and ethics, highlighting resources to report concerns regarding
misconduct, including corruption.

Report an integrity concern


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


ANTI-CORRUPTION TRAINING

We are committed to ensuring our employees understand what is expected of them
and to grow their skills around ethical decision-making. Our training program
focuses on policy requirements, values, and culture-based learning through
in-person and online courses, such as our award-winning Standards of Business
course, anti-corruption workshops, role-targeted training, and integrity skills
programs. We require anti-corruption training for our partners and suppliers.

Find training


STANDARDS OF BUSINESS CONDUCT COURSE

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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.




A SALES QUOTE IS CREATED

The sales team or reseller creates a sales quote in Microsoft’s customer
relationship management (CRM) solution.


THE QUOTE IS SCREENED BY A RISK MODEL

The Compliance Analytics Program applies an algorithm against the quote to
calculate a risk score based on data attributes in real-time.


FLAGGED QUOTES ARE REVIEWED

Compliance personnel review quotes identified as requiring additional scrutiny
and conduct control checks and mitigate any risks with stakeholders and those
involved in the transaction.


DEALS ARE APPROVED OR STOPPED; OUTCOMES FLOW BACK TO ANALYTICS TEAM

The Compliance Analytics Program continues to monitor risks. Compliance
personnel will only approve a quote for processing if identified risks are
mitigated and controls are satisfied. The outcomes are used to improve our
Compliance Analytics Program.


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.

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