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Effective URL: https://www.microsoft.com/en-us/legal/compliance/anticorruption
Submission: On March 13 via api from DE — Scanned from DE
Effective URL: https://www.microsoft.com/en-us/legal/compliance/anticorruption
Submission: On March 13 via api from DE — Scanned from DE
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We use optional cookies to improve your experience on our websites, such as through social media connections, and to display personalized advertising based on your online activity. If you reject optional cookies, only cookies necessary to provide you the services will be used. You may change your selection by clicking “Manage Cookies” at the bottom of the page. Privacy Statement Third-Party Cookies Accept Reject Manage cookies Skip to main content Microsoft Legal Legal Legal * Home * Diversity & inclusion * Microsoft Legal diversity * D&I at Microsoft CELA * Diversifying the legal profession * Law firm D&I partnerships * Compliance & ethics * Our approach Our approach * Microsoft compliance program * Standards of Business Conduct Standards of Business Conduct * Our Trust Code * Upholding our code of conduct * Report a concern * Anti-corruption & anti-bribery Anti-corruption & anti-bribery * Anti-corruption & anti-bribery commitments * Trustworthy representatives * State-owned entity criteria * Environmental compliance Environmental compliance * Devices compliance and sustainability * Cloud responsible packaging * Responsible supplier sourcing * Intellectual property * Patents & licensing Patents & licensing * Microsoft intellectual property * About technology licensing * Tech licensing programs * Microsoft patents * Azure IP Advantage * Copyrights & trademarks Copyrights & trademarks * About copyright law * Use of Microsoft copyrighted content * Microsoft Trademark and Brand Guidelines * Report copyright & trademark infringement * Open innovation Open innovation * Open source * Open data * Licensing terms Licensing terms * License terms lookup * Software & hardware piracy * Microsoft Terms of Use * Third party notices * More resources * Antitrust & interoperability Antitrust & interoperability * Antitrust information * European Commission Decision of 2004 * Interoperability efforts * Arbitration & dispute resolution Arbitration & dispute resolution * US arbitration and dispute resolution * EU arbitration and dispute resolution * Pro Bono Pro Bono * Microsoft pro bono programs * Microsoft pro bono report * Settlement & policy information Settlement & policy information * Consumer Class Action Settlement * Legal supplier policies and procedures * More * All Microsoft * * Microsoft 365 * Office * Windows * Surface * Xbox * Deals * Support * Software Software * Windows Apps * OneDrive * Outlook * Skype * OneNote * Microsoft Teams * Microsoft Edge * PCs & Devices PCs & Devices * Computers * Shop Xbox * Accessories * VR & mixed reality * Phones * Entertainment Entertainment * Xbox Game Pass Ultimate * PC Game Pass * Xbox games * PC games * Windows digital games * Movies & TV * Business Business * Microsoft Cloud * Microsoft Azure * Microsoft Dynamics 365 * Microsoft 365 * Windows 365 * Microsoft Industry * Microsoft Advertising * Shop Business * Developer & IT Developer & IT * .NET * Visual Studio * Windows Server * Windows Dev Center * Docs * Power Platform * Power Apps * HoloLens 2 * Other Other * Microsoft Rewards * Free downloads & security * Education * Virtual workshops and training * Gift cards * Gift Ideas * Licensing * Microsoft Experience Center * View Sitemap Search Search Microsoft Legal Resources Cancel 0 Cart 0 items in shopping cart Sign in to your account Sign in 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 Select Language * Select Language * Arabic * Chinese (Simplified) * Chinese (Traditional) * Czech * English * French * German * Hungarian * Italian * Japanese * Korean * Polish * Portuguese * Romanian * Russian * Spanish * Vietnamese Select Language Arabic Chinese (Simplified) Chinese (Traditional) Czech English French German Hungarian Italian Japanese Korean Polish Portuguese Romanian Russian Spanish Vietnamese Continue 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 Watch the season 2 trailer Watch the season 3 trailer 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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