Microsoft Standards of Business Conduct (en-US) (1)

7/25/2019 Microsoft Standards of Business Conduct (en-US) (1)

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Letter from

Satya Nadella


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01Microsoft Standards of Business Conduct

Dear Fellow Employee,When I came to Microsoft 22 years ago, I believed I couldmake a difference and change the world through tech-

nology. That belief holds true today and together, we areempowering people to do more with the services, tools,applications, and devices we build. Our focus, simply put, isto help our customers and partners thrive in a mobile-rst,cloud-rst world.

Living in a mobile and cloud-rst era means asking peopleand organizations to trust us with their information anddata. Trust is paramount in how we operate and conduct

business with individuals, companies and governments. Webuild and maintain trust through our shared commitmentto ethical behavior and by acting with honesty and integrity.

Our success depends on you. We set high ethical standardsat Microsoft and we expect every employee to live up tothose standards. Complying with the law and companypolicies is the rst and most important job of everyMicrosoft employee. A momentary lapse in judgment by asingle employee has the potential to erode the value andthe trust we bring to customers. As a Microsoft employee,you are expected to maintain a commitment to high ethicalstandards and conduct Microsofts business with integrity.

The Standards of Business Conduct are an extension ofMicrosofts values and reect our continued commitment toethical business practices and complying with the law. Weexpect you to be well informed and exercise good judgmentwhen making business decisions, and the Standards are

designed to help you make the right decisions for yourselfand Microsoft.

The Standards are not intended to cover every issue orsituation you may face as a Microsoft employee. These

Standards summarize, and are supported by, the principlesand policies that govern our company. You should use theStandards, in conjunction with our corporate policies, toguide and inform your conduct. Please use the resourcesdescribed in the Standards to help answer your questions oraddress your concerns. In addition, managers should use theStandards to foster and reward a culture of accountabilityand integrity within their groups.

All Microsoft employees are responsible for understandingand complying with the Standards, Microsoft policies, laws,and regulations. We all have a responsibility to raise compli-ance and ethics concerns, and we want to hear from you ifyou have a concern. Microsoft prohibits retaliation againstany employee who in good faith seeks guidance or reports apossible violation of the Standards.

I rmly believe that Microsoft is the best company in theworld for employees who want to innovate, drive change,make a difference, and do their best work. Thank you forliving our core values and your commitment to ethical andlegal behavior. There must be integrity in everything we do.

Satya Nadella

Chief Executive Ofcer


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01. International Business Activities . . . . . . . . . . . . . . . . . 14

02. Intellectual Property. . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

03. Fair Competition and Antitrust . . . . . . . . . . . . . . . . . . 15

04. Investigations, Inspections, and Inquiries. . . . . . . . . 15

05. Anti-Corruption. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

06. Trade Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

07. Gifts and Hospitality. . . . . . . . . . . . . . . . . . . . . . . . . . . 20

08. Lobbying . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

09. Purchasing Decisions and Practices . . . . . . . . . . . . . . . 23

10. Suppliers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

11. Representatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

12. Condential and Proprietary Information. . . . . . . . . 28

13. Fair Information Practices. . . . . . . . . . . . . . . . . . . . . . . 29

14. Information Management . . . . . . . . . . . . . . . . . . . . . . 29

15. Insider Information and Securities Trading. . . . . . . . . 30

16. Competitive Information. . . . . . . . . . . . . . . . . . . . . . . . 32

17. Social Media . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .32

18. Responsible Business Leadership . . . . . . . . . . . . . . . . 36

19. Citizenship and Community Service . . . . . . . . . . . . . . 36

20. Human Rights. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

21. Political Activities and Contributions . . . . . . . . . . . . . 40

22. Quality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40

23. Sustainability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

Introduction Managing & ProtectingInformation

Working Responsibly &Serving CommunitiesAround the World

Complying with Laws,Regulations & MicrosoftPolicies

Our Core Values . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 04

Our Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 06

Reporting & Guidance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 08

Making Ethical Decisions . . . . . . . . . . . . . . . . . . . . . . . . . . 11


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24. Open, Honest, and Respectful. . . . . . . . . . . . . . . . . . 44

25. Diversity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .44

26. Equal Employment Opportunity . . . . . . . . . . . . . . . 45

27. Use of Information and Technology . . . . . . . . . . . . 46

28. Safety and Health. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

29. Financial Integrity. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50

30. Conicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

31. Fiscal Responsibility. . . . . . . . . . . . . . . . . . . . . . . . . . . 54

32. Use and Protection of Assets. . . . . . . . . . . . . . . . . . . 54

33. Third-Party Software. . . . . . . . . . . . . . . . . . . . . . . . . . 55

34. Communication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55

Providing a Dynamic &Diverse Work Environment

Our Business Conduct &Compliance Program

Managing Our Assets

Responsibly

Administration and Enforcement . . . . . . . . . . . . . . . . . . . 56

Serious Consequences forNot Following the Standards . . . . . . . . . . . . . . . . . . . . . . . 57

Waiving the Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

About this Booklet . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

References to Microsoft and to Employee. . . . . . . . 57


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Our Core ValuesWhat are values? In simplest terms, theyare a set of beliefs that govern behavior.Like people, companies have values.

Our Standards of Business Conducthelp us live our values, whichinclude fullling our commitmentto the highest ethical and legalbehavioras we evolve in a mobile-rst, cloud-rst world.

Our values must shine throughin all our interactions.


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Integrity &honesty

Passion

Open &respectful

Big challenges

Accountable

Self-critical

Integrity and honesty can bedemonstrated in many ways.Honesty and integrity are demon-strated not just in the extraordi-nary but in the everyday decisionswe make. As employees, we strivefor excellence even when no oneelse is looking.

Passion is everywhere you lookat Microsoft. We have a zeal fortechnology and what it enablescustomers to do. We strive to meetcustomer and partner expecta-tions of quality, security, privacy,reliability, and business integrity.

People who are open andrespectful of others understandthat how work is accomplished isas important as the work itself.We never act in a manner thatcould be perceived as threatening,intolerant, or discriminatory.

From the very beginning, Microsofthas tackled big challenges. Bigchallenges have little to do witha specic job and everything todo with the vision, courage, andfortitude of our people. People justlike Bill Gates. People just like you.

Accountability is about keepingyour word and taking responsi-bility for the commitments youmake. When you say youll dosomething, you do it. Trust isbuilt over time in just this way.Be honest and accountable.

Our dedication to quality is notexclusive to our products. Each ofus should improve over time. Wemust consistently ask ourselvesand co-workers, What couldI have done better? How can Iimprove for next time?

Introduction DiversityCommunitiesCompliance AssetsProtect Info Program

Our Core ValuesOur ResponsibilitiesReporting & GuidanceMaking Ethical Decisions


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Our Responsibilities

The Standards apply to Microsoft,and all employees, directors, andexecutive ofcers of Microsoftand its subsidiaries and ControlledAfliates.

The Standards are an extension of Microsoftsvalues and reect our continued commitment toethical business practices and legal compliance.

The Standards are designed to helpyou make the right decisions foryourself and Microsoft.They are notintended to cover every issue or situationyou may face as a Microsoft employee.Nor do they replace other more detailed

policies. You should use the Standardsas a reference guide in addition toMicrosofts policies.


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You are expected to maintain high ethicalstandards, conduct Microsoft businesswith integrity, and work in compliance withMicrosoft policies and the law.

Read, understand, and complywith the Standardsand the Microsoft policies, laws, and regulationsapplicable to your job.

Obtain guidancefor resolving a business practice orcompliance concern or if you are uncertain about howto proceed in a situation.

Report possibleviolations of the Standards, policies,and legal and regulatory requirements.

Be truthful and cooperatefully in any investigations.

Complete annual trainingon the Standards andwhen completed,attest to your understanding of andcommitment to the Standards.

Failure to read or attestto the Standards doesnot excuse you fromresponsibility to complywith the Standards,policies, and regulations

applicable to your job.



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Reporting & Guidance

It is your right and responsibility

to report compliance concernsand obtain guidancewhen you areuncertain about what action youshould take.

You are responsible and account-

able for preventing, detecting,and reporting instances ofnon-compliance to a memberof Microsoft management, HumanResources, Finance, Legal andCorporate Affairs, the Directorof Compliance, or the BusinessConduct Hotline.

We want to hear your concerns and questions.Microsoft has zero tolerance for retaliation.

I t d ti Di itC itiC li A tP t t I f P


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Microsoft does not tolerate retaliationagainst any employee who makes agood faith report, cooperates with aninvestigation or audit, or refuses toparticipate in activities that violateapplicable laws, regulations, companypolicies, or standards of ethical conduct.

Any employee who engages in retalia-tion will be subject to disciplinary action.

Any concerns or issues you report

will be treated seriously, fairly, andpromptly. Microsoft will handleinquiries discreetly and make everyeffort to maintain, within the limitsallowed by the law, the condentialityof anyone requesting guidanceor reporting a possible violation.



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Make a toll-free call to the BusinessConduct Hotline at 1-877-320-MSFT (6738).Outside the United States call collect to1-470-219-7087.

Submit a condential report throughthe Microsoft Integrity Web sitewww.microsoftintegrity.com

The Business Conduct Hotline and Integrity Site arededicated resources available to you 24 hours a day,7 days a week, 365 days a year. They are operated byan external supplier that has trained professionals to

take your calls and reports, in condence, and reportyour concerns to the Microsoft Director of Compliancefor appropriate action. Where permitted by law, yourphone calls and reports may be made anonymously.

Email the Business Conduct Line [email protected]

Send a letter to the Director of Compliance atMicrosoft CorporationLegal and Corporate AffairsOne Microsoft WayRedmond, WA 98052 USA

Send a condential fax to1-425-708-7177

These reporting options, including anonymous

reporting where permitted by law, are encouragedfor any compliance concern or question, includingany issue regarding a questionable accounting orauditing matter.

Use the Business Conduct HotlineYou have several reporting options:

Talking to a member of Microsoft management,Human Resources, Finance, or Legal andCorporate Affairs.

Referring to the online versions of the Standards ofBusiness Conduct (internal and external facing) withlinks to policies and guidance.

Referring to the MS Policy site, where internalpolicies are published. All policies have an ownerand a contact who may be contacted for policyquestions and guidance.

Referring to the self-help resources on LCA Weband other internal sites, which have guidance,

checklists, FAQs, training, and other learning aids.

Use other resourcesYou can also report, seek guidance, and use self-help resources by:

http://www.microsoftintegrity.com/mailto:buscond%40microsoft.com%20?subject=Standards%20of%20Business%20Conductmailto:buscond%40microsoft.com%20?subject=Standards%20of%20Business%20Conducthttp://www.microsoftintegrity.com/


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Making ethical decisionsWe expect you to be well informed and exercise good judgmentwhen making business decisions for Microsoft. Before making abusiness decision, ask yourself the following questions:

If you cannot answer yes or you are not sure, do not make the decision or take theaction until you get additional help and guidance.

Highlights specic requirements of theStandards for special attention.

Identies information provided to helpyou comply with the Standards.

Help in the Standards will be identied by icons:

In addition, we will use icons from Use Other Resources to direct you to self-help resources and detailed information.

Is it consistent withour core values andthe Standards?

We expect you to think throughthe issues and to use availableresources to help, including ourcore values and the Standards.

Is it legal?

We are not expecting you tobe a lawyer or legal expert. Wedo expect you to ask questionsand seek guidance if you arenot sure.

Am I comfortable withothers nding outabout my decision?

If you would not be comfort-able sharing your decision withfriends, family, and co-workers,it probably is not the rightthing to do.



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Complying with Laws,

Regulations &Microsoft PoliciesMicrosoft is a global company, and our business is subjectto the laws of many different countries. Each day we interactwith a variety of individuals and groupsincluding ourcustomers, partners, competitors, co-workers, shareholders,

suppliers, representatives, regulatory agencies, andgovernment ofcials. We are committed to interacting withall of these audiences in a respectful, ethical manner and incompliance with legal requirements.

We would rather miss out on business thancompromise our integrity.


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Microsoft acknowledges and respects the

diverse cultures, customs, and businesspractices it encounters in the international

marketplace. Microsoft will comply with boththe applicable U.S. laws and regulations that

govern its operations and local laws wherever

it does business.

We comply with the laws and regulations that

govern the rights to and protection of our ownand others intellectual property including copy-

rights, trademarks, patents, and trade secrets.

01. 02.InternationalBusiness Activities

IntellectualProperty



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We comply with the laws and regulations

designed to promote healthy competition.Antitrust laws and fair competition laws

generally prohibit activities that restrain tradeand restrict competition. We conduct our

business in compliance with these laws.

We are direct, honest, and truthful in our

discussions with agency representatives andgovernment ofcials. During investigations,

inspections, and inquiries we work with Legaland Corporate Affairs and cooperate by

responding promptly to appropriate requests

for information.

03. 04.Fair Competitionand Antitrust

Regulatory Investigations,Inspections, and Inquiries


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Understand the keypoints of ourAnti-Corruption Policy:

Do not offer or pay bribes to anyone.

Know your representative.

Charitable donations may not benet ofcials.

Transactions should be transparent.

Travel and lodging for ofcials must

be appropriate and pre-approved.

Gifts and hospitality for ofcials shouldbe infrequent and reasonable.

Hiring decisions may not benetgovernment ofcials.

Facilitating payments are prohibited.

Money laundering is prohibited.

Keep accurate books and records.

Report actual or suspected violationsand seek advice.

Retaliation for reporting concerns

is not tolerated.


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Microsoft complies with the laws andregulations related to the export, re-export,

import, and use of our software, products,devices, components, services, and technical

data. These trade controls place complianceobligations on Microsoft and on our

suppliers or partners related to internationaldistribution of Microsoft products, services,

or assets.

06.Trade Controls

Global Trade Compliance Policy

https://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/GlobalTrade/Pages/Global%20Trade%20Compliance.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/GlobalTrade/Pages/Global%20Trade%20Compliance.aspx


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TradeNet

All employees need to be aware of their responsibilitiesfor trade compliance. If you have responsibility forthe design, manufacture, sale, or maintenance ofMicrosofts products or services, review theguidelines outlined in the TradeNet internal site.

Sanctions

Global political events directly impact Microsoftbecause government bodies can implementsanctions, subjecting countries and individuals totrade embargoes. These actions have direct impacton Microsoft policies, which can range from banson providing cloud services and devices to freezingrevenue collections and nancial refunds tocountries, companies, or individuals.

Devices with encryptionTo protect customer data, Microsoft products maycontain encryption. Many countries have encryptionexport and import requirements on physical anddigital distribution before shipments commence.

Export compliance terms & conditions

If you are writing a contract, negotiating a partneragreement, or engaged in any activity where agree-ments are intended to protect Microsoft from violatingglobal export controls, you should use our standardexport clauses or engage directly with the MicrosoftGlobal Trade Organization when negotiating.

Cloud services export restrictions

Several countries are developing export restrictionson cloud services and data. Potential cloud customersmay request assurances that their data will behosted in compliance with the global export andencryption controls.

TradeNet

Standard Export Clause

Global Encryption Controls

Key information abouttrade controls:
http://aka.ms/tradenethttps://microsoft.sharepoint.com/teams/Tradenet/Pages/Standard_Export_Clause_Process_DOCUMENT.aspxhttps://microsoft.sharepoint.com/teams/Tradenet/Pages/Global-Encryption-Controls.aspxhttps://microsoft.sharepoint.com/teams/Tradenet/Pages/Global-Encryption-Controls.aspxhttps://microsoft.sharepoint.com/teams/Tradenet/Pages/Standard_Export_Clause_Process_DOCUMENT.aspxhttp://aka.ms/tradenet


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Microsoft requires the use of good judgment,discretion, and moderation when giving

or accepting gifts or hospitality in businesssettings. Gift giving and hospitality practices

may vary in different cultures; however, anygifts and hospitality given or received must

be in compliance with the law, not violatethe policies of the giver or recipient, and beconsistent with local custom and practice.

07.Gifts andHospitality

We do not solicit gifts, hospitality, or favorsof any value from persons or rms with

which Microsoft does business currently orprospectively. Nor do we act in a manner that

would place any supplier, partner, or customerin a position where he or she may feel obligated

to make a gift, provide hospitality, or providepersonal favors in order to do business orcontinue to do business with Microsoft.



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Some gifts are always prohibited:

Money or cash equivalents.

A bribe, kickback, or anything with corrupt intent.

Using personal funds to accomplish what isotherwise prohibited by policy.

Gifts or hospitality to a government ofcialsfriends or family.

Anything of value that might create theappearance of impropriety or result inembarrassment to Microsoft.

Understand gifts and hospitality basics:

Any gifts and hospitality given orreceived must:

Be reasonable.

Have a legitimate business purpose.

Not interfere with the exercise of independent

judgment in the best interests of Microsoft.

Comply with the law.

Be consistent with local custom and practice.

Not violate the givers or receivers policieson the matter.

Gift, Hospitality & Travel Policy

Gifts & Hospitality for Government Ofcials

Travel & Lodging for Government Ofcials

Gifts, Hospitality, and Travel
https://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/GiftsHospitalityAndTravel/Pages/Gift%20Policy.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/AntiCorruption/Pages/Gifts%20amp%20Hospitality%20for%20Government%20Officials.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/AntiCorruption/Pages/Travel%20and%20Lodging%20for%20Government%20Officials.aspxhttp://lcaweb/policies/Gifts/Pages/Gifts,EntertainmentandTravel.aspxhttp://lcaweb/policies/Gifts/Pages/Gifts,EntertainmentandTravel.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/AntiCorruption/Pages/Travel%20and%20Lodging%20for%20Government%20Officials.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/AntiCorruption/Pages/Gifts%20amp%20Hospitality%20for%20Government%20Officials.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/GiftsHospitalityAndTravel/Pages/Gift%20Policy.aspx


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We recognize our right and responsibilityto lobby on behalf of issues that affect our

company and business operations. We complywith applicable political lobbying regulations.

08.Lobbying



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In our purchasing decisions, negotiations,contract development, and contract

administration, we comply with theapplicable laws and regulations that

govern those relationships and expectthe same from our suppliers.

09.Purchasing Decisionsand Practices

Procurement Code of Professional Conduct
http://msw/WorkplaceServices/Purchasing/Vendors/VendorManagement/Policies/CodeofConduct/Pages/default.aspxhttp://msw/WorkplaceServices/Purchasing/Vendors/VendorManagement/Policies/CodeofConduct/Pages/default.aspx


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Microsoft suppliers must adhere to the higheststandards of ethical behavior and regulatory

compliance and operate in the best interest ofMicrosoft. Suppliers are expected to provide

high-quality services and products while main-taining exibility and cost-effectiveness. All

suppliers are required to read and comply withthe Microsoft Supplier Code of Conduct and

train their personnel on the requirements of the

Supplier Code.

All suppliers are required to read andcomply with the Anti-Corruption Policy for

Microsoft Representatives and train theiremployees and personnel on compliance

with anti-corruption laws.

Channel partners, Microsoft Partner Networkmembers, and other Microsoft representatives

must adhere to the highest standards of ethicalbehavior and regulatory compliance when they

sell, distribute, or market Microsoft products

and services. All representatives are required to

read and comply with the Anti-Corruption Policyfor Microsoft Representatives and train theiremployees and personnel on compliance with

anti-corruption laws.

No Microsoft representative shall pay or offer to

pay a bribe, or provide another thing of value for

the purpose of obtaining an improper benetto any third party, public or private, with whomMicrosoft is doing business or is aiming to do

business with in the future.

10. 11.Suppliers Representatives



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We expect our suppliers, partners, and otherrepresentatives to adhere to the highest standardsof ethical behavior and legal compliance when

they are working on our behalf.Employees should deal only with representatives who are legitimate, qualied businesses with areputation for integrity.

Microsofts Anti-Corruption Policyfor Representatives

Microsoft Supplier Code of Conduct

Anti-Corruption Training forMicrosoft Partners

Microsoft Supplier Compliance Training
http://download.microsoft.com/download/8/6/D/86D7BB27-55FB-4098-AF89-2EAA0210B22A/Anti-Corruption%20Policy%20For%20Representatives.docxhttp://download.microsoft.com/download/8/6/D/86D7BB27-55FB-4098-AF89-2EAA0210B22A/Anti-Corruption%20Policy%20For%20Representatives.docxhttp://www.microsoft.com/about/companyinformation/procurement/process/en/us/contracting.aspx#SupplierCodeofConducthttp://www.microsoft.com/en-us/legal/courseLauncher.htmhttp://www.microsoft.com/en-us/legal/courseLauncher.htmhttp://www.microsoft.com/about/companyinformation/procurement/vcc/index.htmlhttp://www.microsoft.com/about/companyinformation/procurement/vcc/index.htmlhttp://www.microsoft.com/en-us/legal/courseLauncher.htmhttp://www.microsoft.com/en-us/legal/courseLauncher.htmhttp://www.microsoft.com/about/companyinformation/procurement/process/en/us/contracting.aspx#SupplierCodeofConducthttp://download.microsoft.com/download/8/6/D/86D7BB27-55FB-4098-AF89-2EAA0210B22A/Anti-Corruption%20Policy%20For%20Representatives.docxhttp://download.microsoft.com/download/8/6/D/86D7BB27-55FB-4098-AF89-2EAA0210B22A/Anti-Corruption%20Policy%20For%20Representatives.docx


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Managing

& ProtectingInformationAll of us create, use, and learn differenttypes of information in the course of doingour jobs. Appropriately managing andprotecting this information is important in

helping us conduct Microsoft business withintegrity, work in compliance with the law,and maintain high ethical standards.

Condential and Proprietary Information



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Fair Information PracticesInformation ManagementInsider Information and Securities TradingCompetitive InformationSocial Media


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We respect our ethical and legal responsi-

bilities to protect Microsoft condential andproprietary non-public information and

communicate it only as necessary to conductMicrosoft business. We do not use this

information for our personal advantage or

for non-Microsoft business use, and maintainthis condentiality even after Microsoft nolonger employs us.

12.Condential andProprietary Information

Protect condentialand proprietaryinformation:

Do notshare our condential information withfriends, family members, or former Microsoftcolleagues or employees.

Do notdiscuss condential information in publicplaces where third parties may overhear, includingcompany cafeterias and non-secure hallwaysand lobbies.

Do notwork with documents containingcondential information (either in hard copy orelectronically) in public places if third parties cansee them.

Dodiscuss our condential information with otheremployees only on a need-to-know basis.

Doalways restrict access to condential information

posted on the intranet and SharePoint sites.

Doreview the Social Media Guidelines andCondential Information Policy.

Condential Information Policy

Guidelines for Engaging with Social Media

https://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/ConfidentialInfo/Pages/Confidential%20Information%20Policy.aspxhttp://lcaweb/marketing/SocialMedia/Pages/Guidelines.aspxhttp://lcaweb/marketing/SocialMedia/Pages/Guidelines.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/ConfidentialInfo/Pages/Confidential%20Information%20Policy.aspx


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Our business is built around technologies

to manage information, and we treat thatinformation with condentiality and integrity.

We are committed to creating a trustworthyenvironment for Internet users, and continu-

ally striving to protect their online privacy

is at the core of this commitment. We haveadopted privacy practices, developed tech-nological solutions to empower individuals to

help protect their online privacy, and continue

to educate consumers about how they canuse these tools to manage their personally

identiable information while they use

the Internet.

We create, retain, and dispose of our business

records and information assets, both writtenand electronic, as part of our normal course

of business. Microsoft provides prescriptiveretention requirements, best practices, and

policies that map to our legal obligations

and long-term business needs.

13. 14.Fair InformationPractices

InformationManagement

Document Retention Policy and CorporateRetention Schedule

http://privacy
http://lcaweb/policies/EmployeeConduct/retention/Pages/DocumentRetentionPolicy.aspxhttp://lcaweb/policies/EmployeeConduct/retention/Pages/DocumentRetentionPolicy.aspxhttp://privacy/http://privacy/http://lcaweb/policies/EmployeeConduct/retention/Pages/DocumentRetentionPolicy.aspxhttp://lcaweb/policies/EmployeeConduct/retention/Pages/DocumentRetentionPolicy.aspx


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In the course of doing business for Microsoft orin discussions with one of our customers, vendors,

or partners, we may become aware of material

non-public information about that organization.

Information is considered material if there is a

substantial likelihood that a reasonable investorwould consider it important in making a decisionto trade in the public securities of the company.

Individuals who have access to this type ofinformation are called insiders. We discuss

this information on a limited, need-to-know

basis internally, and do not share it with anyone

outside Microsoft.

15.Insider Informationand Securities Trading

We do not buy or sell the public securities ofa company, including our own, on the basis of

such information, and we do not share (tip)

this information with others. Because of thecomplexity of the analysis and severe penalties

associated with insider trading and tipping,

contact Legal and Corporate Affairs before youbuy or sell public securities in situations whereyou may be in possession of material nonpublic

information.



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You may not trade Microsoft stock when youhave material, non-public information.

You may not disclose material, non-publicinformation to any third party who then trades inMicrosoft stock (tipping).

You cannot trade or tip stock of another companywhile in possession of material non-public infor-

mation obtained in connection with your employ-ment at Microsoft (for example, you becomeaware of a pending Microsoft acquisition).

If you are an ofcer of the company (CorporateVice President and above) or are identied byMicrosoft as having routine access to material,non-public information in connection with your

job responsibilities, you may only buy or sell

Microsoft stock within a specic window followingeach quarterly earnings announcement.

Avoid insidertrading:

General Insider Training Policy
https://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/InsiderTrading/Pages/General%20Insider%20Trading%20Policy.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/InsiderTrading/Pages/General%20Insider%20Trading%20Policy.aspx


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Microsoft has an obligation and is entitled to

keep up with developments in our industry,including obtaining information about our

competitors. We obtain information aboutour competitors through honest, ethical, and

legal methods.

We recognize the role that social media playsin communications and society today. We willprotect condential information and exercise

good judgment when participating in socialmedia and networking.

16. 17.CompetitiveInformation

Social Media

Guidelines for Engaging with Social Media

Condential Information PolicyCompetitive Intelligence Policy

http://lcaweb/marketing/SocialMedia/Pages/Guidelines.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/ConfidentialInfo/Pages/Confidential%20Information%20Policy.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/ConfidentialInfo/Pages/Competitive%20Intelligence%20Policy.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/ConfidentialInfo/Pages/Competitive%20Intelligence%20Policy.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/ConfidentialInfo/Pages/Confidential%20Information%20Policy.aspxhttp://lcaweb/marketing/SocialMedia/Pages/Guidelines.aspx


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Domake clear your Microsoft afliation.

Dorecognize that anything you say can beviewed as an ofcial company statement.

Do notannounce things that are not yoursto announce, but do support major companyannouncements.

Doprotect condential information.

Dobe honest, accurate, and ethical at all times.

Dounderstand the consequences of your actions.

When blogging and postingon social media sites:


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Working

Responsibly &Serving CommunitiesAround the WorldMicrosoft has an enduring commitment to fullling our

public responsibilities and serving the needs of peoplein communities worldwide. We are a responsible globalcorporate citizen. We build and maintain the trust of ourcustomers, consumers, partners, and shareholders.

Responsible Business LeadershipCitizenship and Community ServiceH Ri ht



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Human RightsPolitical Activities and ContributionsQualitySustainability


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We manage our business responsibly in orderto maintain the condence, respect, and

trust of our customers, consumers, partners,shareholders, and other audiences. We are

committed to acting with integrity, investing innew product development, being responsive

and accountable to our customers and partners,and remaining a leader in our eld. We under-

stand the responsibility that comes with being

a worldwide technology and business leaderand accept our unique role in both our industry

and the global business community.

We have a strong and demonstratedcommitment to the improvement of society as

well as the communities in which we operate.We encourage the support of charitable,

civic, educational, and cultural causes. Our

contributions include cash, volunteer time,software, and technical assistance.

18. 19.Responsible BusinessLeadership

Citizenship andCommunity Service

http://citizenship

http://give

http://microsoft.com/citizenshiphttp://give/http://give/http://microsoft.com/citizenship


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Our Global Human Rights Statement aligns with:

United Nations (UN) Guiding Principles on Businessand Human Rights

UN Universal Declaration of Human Rights

UN International Covenant on Civil and Political Rights

UN International Covenant on Economic, Social, andCultural Rights

International Labour Organization Declaration onFundamental Principles and Rights at Work

Onlineprivacy

Human

trafcking Child onlinesafety

Conict minerals

and labor rightsFreedom ofexpression Datasecurity

As a global company, we address importanthuman rights issues every day.


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Employees are encouraged to exercise theirright to participate in political activities. Any

decision to become involved is entirely personaland voluntary.

Employees personal political activities are done

on their own time and with their own resources.

Our success depends on creating new andcompelling products and services, while also

building strong relationships with our customersand partners. Listening and responding to

customers is core to our business. We keep intouch through online feedback, support commu-

nities, product satisfaction surveys, usability

studies, research forums, and our customerservice representatives.

The insight we gain helps us understand

and respond to our customers and partnersexperiences.

21. 22.Political Activities andContributions

Quality

http://cpe

Public Advocacy by MicrosoftEmployees Policy

Introduction

DiversityCommunitiesCompliance AssetsProtect Info Program
http://cpe/https://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/WorkEnvironment/Pages/Public%20Advocacy%20by%20Microsoft%20Employees.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/WorkEnvironment/Pages/Public%20Advocacy%20by%20Microsoft%20Employees.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/WorkEnvironment/Pages/Public%20Advocacy%20by%20Microsoft%20Employees.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/WorkEnvironment/Pages/Public%20Advocacy%20by%20Microsoft%20Employees.aspxhttp://cpe/


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Technology can help create a more sustain-able future. We operate sustainably to minimize

the environmental and social impacts of ouractivities. We are making our operations

leaner through efciency initiatives, greenerby purchasing renewable energy, and more

accountable by cascading an internal carbon

fee across our business.

23.Sustainability

http://environment
http://sharepoint/sites/environment/SitePages/default.aspxhttp://sharepoint/sites/environment/SitePages/default.aspx


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Providing a Dynamic

& Diverse WorkEnvironmentOur employees passion fuels our success in a competitive,rapidly changing industry. Staying on top requires hiringthe best talent around the world and investing in theirpotential. To attract and retain exceptional people,

we provide a dynamic and diverse work environmentthat fosters collaboration and celebrates personal andprofessional growth.


Open, Honest, and RespectfulDiversityEqual Employment OpportunityUse of Information and Technology


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Use of Information and TechnologySafety and Health


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In our relationships with each other, we striveto be open, honest, and respectful in sharing

our ideas and thoughts, and in receiving input.

Microsoft promotes and supports a diverseworkforce at all levels of the company. It is our

belief that creating a work environment thatenables us to attract, retain, and fully engage

diverse talents leads to enhanced innovationand creativity in our products and services.

24. 25.Open, Honest,and Respectful

Diversity

http://hrweb/lifeatmicrosoft/diversity

http://hrweb/lifeatmicrosoft/diversityhttp://hrweb/lifeatmicrosoft/diversity


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Microsoft promotes a cooperative andproductive work environment by supportingthe cultural and ethnic diversity of its workforce.

Our collective challenge is to enhance the

companys performance through valuing andunderstanding differences.

Microsoft is committed to a policy of providingequal employment opportunity to all qualiedemployees and applicants. This commitment is

reected in all aspects of our daily operations.We do not discriminate on the basis of race,

color, sex, sexual orientation, gender identity

or expression, religion, national origin, maritalstatus, age, disability, veteran status, or genetic

26.Equal EmploymentOpportunity

information in any personnel practice, includingrecruitment, hiring, training, compensation,promotion, and discipline. We do not discrimi-

nate based on any other characteristic protected

by applicable state or local law where a partic-ular employee works.

It is the policy of Microsoft to provide reasonableaccommodation to qualied employees whohave protected disabilities to the extent required

by federal law and any state or local law where aparticular employee works.

Equal Employment Opportunity Policy
https://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/WorkEnvironment/Pages/Equal%20Employment%20Opportunity%20Policy.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/WorkEnvironment/Pages/Equal%20Employment%20Opportunity%20Policy.aspx


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At all times, we must use good judgment andcommon sense; conduct ourselves ethically,

lawfully, and professionally; and follow appli-cable authorization protocols while accessing

and using company-provided technology,devices, or services, and related content.

In using company devices and services, we donot create, access, store, print, solicit, or send

any material that is intimidating, harassing,threatening, abusive, sexually explicit, or

otherwise offensive or inappropriate, nor dowe send any false, derogatory, or malicious

communications.

Were committed to creating a safe and healthywork environment by integrating sound safety

and health practices within our operations. Wecomply with applicable workplace safety and

health regulations.

27. 28.Use of Informationand Technology

Safety andHealth

http://lcaweb/policies/workplace

Sexually Explicit or Otherwise Offensive Material

Information Technology Guidelines and Policies

Company Access and Monitoring Informationand Property

http://lcaweb/policies/workplacehttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/WorkEnvironment/Pages/Sexually%20Explicit%20or%20Otherwise%20Offensive%20Material.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/WorkEnvironment/Pages/Information%20Technology%20Guidelines%20and%20Policies.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/WorkEnvironment/Pages/Company%20Access%20and%20Monitoring%20Information%20and%20Property.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/WorkEnvironment/Pages/Company%20Access%20and%20Monitoring%20Information%20and%20Property.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/WorkEnvironment/Pages/Company%20Access%20and%20Monitoring%20Information%20and%20Property.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/WorkEnvironment/Pages/Company%20Access%20and%20Monitoring%20Information%20and%20Property.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/WorkEnvironment/Pages/Information%20Technology%20Guidelines%20and%20Policies.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/WorkEnvironment/Pages/Sexually%20Explicit%20or%20Otherwise%20Offensive%20Material.aspxhttp://lcaweb/policies/workplace


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Managing Our

Assets ResponsiblyEach day we are entrusted with Microsoft assetsand resources. We are committed to using them

responsibly and not for our personal benet.We act in Microsofts best interests, and withhonesty and integrity. We avoid self-dealing andactual or perceived conicts of interest.


Financial IntegrityConicts of InterestFiscal ResponsibilityUse and Protection of AssetsThi d P t S ft


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Third-Party SoftwareCommunication


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We honestly and accurately record andreport business information. We comply withall applicable local, state, and federal laws

regarding record completion and accuracy.

We require that nancial transactions beexecuted in accordance with managements

authorization, and recorded in a proper

manner in order to maintain accountabilityfor Microsoft assets. Our nancial informa-tion reects only actual transactions and is in

compliance with Microsoft and other appli-cable accounting practices. The CEO, CFO,

Corporate Controller, and other employees of

the nance organization are also required to

comply with the policies.

29.FinancialIntegrity

Prohibitedtransactions:

Side Agreements.Contract documents must reectthe totality of the agreement and include all termsand concessions agreed to by Microsoft and thecounterparty.

Nonstandard Billing or Payment Arrangements.Do not change billing terms in a manner that isinconsistent with our contractual agreements.

Nonstandard Agreements.Do not use nonstandardagreements in place of Microsofts standard agreementtemplates and processes.

Improper Dealings.Do not structure or manipulatetransactions or agreements for personal benet or toimproperly benet a third party. Revenue, quota, orbudget manipulation is prohibited.

Microsoft Finance Code of Professional Conduct

Financial Integrity Policy

https://microsoft.sharepoint.com/sites/mspolicy/CentralizedFunctions/Finance/FinanceCodeofConducthttps://microsoft.sharepoint.com/sites/mspolicy/CentralizedFUNCTIONS/SMSG/SMSGIntegrity/FinancialIntegrity/Pages/Financial%20Integrity%20Policy.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CentralizedFUNCTIONS/SMSG/SMSGIntegrity/FinancialIntegrity/Pages/Financial%20Integrity%20Policy.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CentralizedFunctions/Finance/FinanceCodeofConduct


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We act in the best interests of Microsoft andexercise sound judgment unclouded bypersonal interests or divided loyalties.

We avoid the appearance, as well as a reality,of a conict of interest.

You are expected to disclose conict of interestsituations and seek guidance where necessaryfrom your manager or Human Resources

Business Partner.

30.Conicts ofInterest



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Report.Promptly report any actual or potentialconict of interest to your manager before takingany further action.

Remove or remediate.After reporting, addressthe conict:

Most often, you will need to remove yourself fromthe conicting situation.

In some cases, you may be permitted to engagein the activity if you obtain the approval of yourmanager and take steps to remediate the conict.

Disclose and obtain approval using theConict of Interest Tool

A conict of interest exists if your circumstanceswould lead a reasonable person to questionwhether your motivations are in the best interestsof Microsoft. A conict of interest can arise in

many situations, including:

Family and romantic relationships with ouremployees or the employees of our suppliers,partners, or customers.

Giving or receiving gifts, hospitality, or travel.

Outside work activities.

Dealing with family members employed by avendor or partner.

Dealing with a vendor or partner who employsfamily members.

Dealing with a vendor or partner in which youor a family member have a nancial interest.

Recognize a conict of interest:

Conict of Interest

Employee-Vendor Conict of Interest

Employment Outside MicrosoftMoonlighting

Family and Romantic Relationships

Conict of Interest Tool
https://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/Conflicts/Pages/Conflict%20of%20Interest.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/Conflicts/Pages/Employee%20-%20Vendor%20Conflict%20of%20Interest.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/Conflicts/Pages/Employment%20Outside%20Microsoft%20Moonlighting.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/Conflicts/Pages/Family%20and%20Romantic%20Relationships%20Avoiding%20Conflicts%20of%20Interest%20at%20Work.aspxhttp://finweb/smsg/controlcompliance/coi/Pages/answerSurvey.aspxhttp://finweb/smsg/controlcompliance/coi/Pages/answerSurvey.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/Conflicts/Pages/Family%20and%20Romantic%20Relationships%20Avoiding%20Conflicts%20of%20Interest%20at%20Work.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/Conflicts/Pages/Employment%20Outside%20Microsoft%20Moonlighting.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/Conflicts/Pages/Employee%20-%20Vendor%20Conflict%20of%20Interest.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/Conflicts/Pages/Conflict%20of%20Interest.aspx


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We exercise good stewardship over and spendMicrosofts funds in a responsible manner.

We wisely use and protect the assets of thecompany, including property (both physicaland intellectual), supplies, consumables, and

equipment. We use these assets exclusively forMicrosofts business purposes.

31. 32.FiscalResponsibility

Use and Protectionof Assets

Procurement Code of Professional Conduct

http://msw/WorkplaceServices/Purchasing/Vendors/VendorManagement/Policies/CodeofConduct/Pages/default.aspxhttp://msw/WorkplaceServices/Purchasing/Vendors/VendorManagement/Policies/CodeofConduct/Pages/default.aspx


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We use software and other content informationwhen permitted by their associated licensesand/or terms of use, or applicable law (e.g., as

a fair use). We prohibit the making or usingof copies of non-licensed copyrighted material,

including software, documentation, graphics,photographs, clip art, animation, movie/video

clips, sound, and music, unless permitted byapplicable law as determined by Legal and

Corporate Affairs.

We establish and maintain clear, honest, andopen communications; listen carefully; andbuild our relationships on trust, respect, and

mutual understanding.

We apply standards of full, fair, accurate, timely,and understandable disclosure in reports and

documents that are led or submitted to theU.S. Securities and Exchange Commission as

well as in other public communications.

We are accountable and responsive to theneeds of our customers, consumers, and

partners and take our commitments to themseriously. Our advertising, sales, and promo-

tional literature seeks to be truthful, accurate,and free from false claims.

33. 34.Third-PartySoftware

Communication

Industry Analyst Financial Disclosure Policy

Microsoft Corporation Disclosure Policy

http://lcaweb/policies/employeeconduct/

copyrighted

http://lcaweb/marketing

Copyright Policy

Our Business
https://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/ConfidentialInfo/Pages/Industry%20Analyst%20Financial%20Disclosure%20Policy.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/ConfidentialInfo/Pages/Microsoft%20Corporation%20Disclosure%20Policy.aspxhttp://lcaweb/policies/employeeconduct/copyrightedhttp://lcaweb/policies/employeeconduct/copyrightedhttp://lcaweb/marketinghttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/ConfidentialInfo/Pages/Proper%20Use%20of%20Microsoft%20and%20Third%20Party%20Copyrighted%20Material.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/ConfidentialInfo/Pages/Proper%20Use%20of%20Microsoft%20and%20Third%20Party%20Copyrighted%20Material.aspxhttp://lcaweb/marketinghttp://lcaweb/policies/employeeconduct/copyrightedhttp://lcaweb/policies/employeeconduct/copyrightedhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/ConfidentialInfo/Pages/Microsoft%20Corporation%20Disclosure%20Policy.aspxhttps://microsoft.sharepoint.com/sites/mspolicy/CORPORATEPOLICIES/ConfidentialInfo/Pages/Industry%20Analyst%20Financial%20Disclosure%20Policy.aspx


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Our Business

Conduct &

Compliance ProgramAdministration and EnforcementThe Standards and Microsofts Business Conduct andCompliance Program (the Program) are endorsed by andhave the full support of the Board of Directors. The Board ofDirectors and management are responsible for overseeingcompliance with and enforcing the Standards.

The General Counsel serves as the companys ChiefCompliance Ofcer and has overall responsibility for themanagement of the Program. The General Counsel reportsdirectly to the CEO and, for this purpose, to the AuditCommittee of the Board of Directors. The General Counsel,through the Deputy General Counsel and Vice Presidentfor the Ofce of the General Counsel, oversees the Ofce ofLegal Compliance (OLC).

The OLC, among other things, applies and interpretsthe Standards, manages the intake and investigation ofcompliance concerns, disseminates ethics and compliancetrainings and communications, and assists with the designand implementation of preventive compliance measures.

The OLC is managed by the Director of Compliance whoreports to the Deputy General Counsel and Vice Presidentfor the Ofce of the General Counsel. The Deputy GeneralCounsel and Director of Compliance have direct access andreporting obligations to the Audit Committee of the Boardof Directors. In administering the Program, the OLC worksclosely with the rest of Legal and Corporate Affairs, Finance,Human Resources, Internal Audit, and other groups focusedon ensuring compliance.



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Serious Consequences for Not Following the Standards

Violations of the Standards are not tolerated. Consequencesfor violations may include disciplinary action, up to andincluding termination of employment, and possible civilor criminal liability. Individuals who have willfully failed toreport known violations by others may also be subject to

disciplinary action.

Any employee who makes a knowingly false report of apossible violation for the purpose of harming anotherindividual may be subject to disciplinary action.

Waiving the Standards

Only the Board of Directors may waive a provision of the

Standards for a director or executive ofcer. Any waiver thatis granted to a director or executive ofcer will be publiclydisclosed as required by NASDAQ listing requirements andapplicable laws, rules and regulations.

About This Booklet

Updated versions of this booklet may be provided toemployees. The most current version of the Standards isfound on Microsoft.com and LCAWeb.

References to Microsoft and Employees

All references to Microsoft include Microsoft Corporationand its subsidiaries and afliates in which it directly orindirectly owns more than 50% of the voting control(Controlled Afliates) unless otherwise specied. Allreferences to employees include directors, executive

ofcers, and employees of Microsoft Corporation and itssubsidiaries or Controlled Afliates.

The Standards are not intended to and do not create anemployment contract, and do not create any contractualrights between Microsoft and its employees or create anyexpress or implied promise for specic treatment in specicsituations. Your employment relationship with Microsoft canbe terminated at any time for any reason with or without

cause unless prohibited by local law, your employmentcontract, or a written agreement signed by an authorizedvice president.

This booklet was produced with sustainable printing practices, using soy based inks at a carbon-neutralfacility. Greenhouse gas emissions from the paper lifecycle, the transport, and the printing of this item havebeen offset through investments in energy efciency and non-fossil fuel energy technologies.


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Business Conduct Line: 1-877-320-MSFT (6738)Outside the U.S.: 1-470-219-7087

Microsoft Integrity website:www.microsoftintegrity.com

Email the Business Conduct Line:[email protected]

Microsoft Corporation,

Legal and Corporate AffairsOne Microsoft WayRedmond, WA 98052 USA

Fax: 1-425-708-7177

Reporting options Icons used in booklet

Specic requirement of the Standards

Information to help you comply with

the Standards

Microsoft policy

Self-help resource

Online Standards (internal and external facing)

Date of Issue: July 2014. 2014 Microsoft Corporation. All rights reserved.
http://www.microsoftintegrity.com/mailto:buscond%40microsoft.com%20?subject=Standards%20of%20Business%20Conductmailto:buscond%40microsoft.com%20?subject=Standards%20of%20Business%20Conducthttp://www.microsoftintegrity.com/

Microsoft Standards of Business Conduct (en-US) (1)

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