Equal Employment Opportunity Policy internal only. Global diversity and inclusion. We treat others with respect and do not tolerate harassment or discrimination. We integrate sound safety and health practices into our operations and comply with workplace safety regulations. We resolve problems respectfully, and never resort to acts or threats of violence. We do not work under the influence of drugs or alcohol.
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.
Conflicts of Interest Policy internal only. Employment Outside Microsoft Policy internal only. 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. 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. 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. 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.
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.
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. We protect and respect the business value of information and ideas, whether they belong to Microsoft or another company.
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.
We never buy or sell any securities based on material, nonpublic information. We do not recommend or suggest that anyone else trade in the securities of any company based on material non-public 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.
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 use standard agreements and contracting processes or get approval for custom terms.
When we retain and dispose of documents, we follow established corporate retention requirements that meet our legal obligations and long- term business needs. 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.
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. Financial Information Disclosure Policy internal only. Social Media Guidelines internal only. Public Advocacy Policy internal only. 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. Responsible Use of Technology Policy internal only. Expense Policy internal only. By not using confidential information for non-Microsoft business use and maintaining confidentiality even if we stop working for Microsoft.
By not using or copying third-party copyrighted materials, like software, graphics, videos, and music, without a license or permission from CELA. Confidential Information Policy internal only. Copyright Policy internal only. 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 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. 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. 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. 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.
Trustworthy Representative Policy internal only. Accessed March 4, Accessed Oct. Accessed Sep. Vanguard Group Inc. BlackRock Inc. State Street Corp. Business Insider. The Verge. We continually evolve our programs to meet these goals.
To prevent compliance issues from arising in the first place, we focus on promoting a culture of ethics and integrity. We do this through creating a culture of compliance throughout our company, and through our Standards of Business Conduct, policies, and training, while also using data analytics, risk assessment, proactive investigations, third party vetting, and other compliance efforts to minimize potential risks.
Compliance is a team effort at Microsoft. Every employee is responsible for upholding our standards, fostering the culture of compliance in their Microsoft team and partners, and reporting concerns.
We strive to assess the root cause of problems, and continually enhance our controls and processes to minimize the risk of recurrence. This process is a core component of our compliance program and growth mindset culture. We achieve our mission by building trust with people and organizations around the globe. Our goals are only possible when people trust Microsoft and trust our technology. We achieve more when we apply our culture and values to build and preserve trust with our customers, governments, investors, partners, representatives, and each other.
Employees who violate our standards face disciplinary action, up to and including termination of employment. Our policies make anyone who engages in retaliation against someone for raising a compliance concern subject to disciplinary action up to and including termination of employment. Our Trust Code reflects our culture and values, and the principles that guide our behavior.
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