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Benchmarking Alert: Here’s the full Microsoft anti-corruption policy

Microsoft has one of the most interesting anti-corruption policies we’ve reviewed and the only one to cover two rarely acknowledged topics: extortion and threats.

1. Why we don’t pay bribes.

As described in our Standards of Business Conduct, Microsoft’s business relies on the trust we build with our customers, partners and suppliers. Offering or paying bribes or kickbacks breaks that trust. Bribery influences the decisions made by our customers and is inconsistent with Microsoft’s mission to empower every individual and organization on the planet to achieve more.

2. You won’t be punished if Microsoft loses out.

You will not be punished for refusing to pay or take a bribe or kickback, even if your refusal results in a loss of business to Microsoft.

3. The extortion defense. 

Imminent Threats: If there is an imminent threat to your health or safety, such as a threat of physical violence, you may provide a payment to avoid immediate harm. Loss of business to Microsoft is not an imminent threat. Whenever possible, you should first consult with and obtain authorization from the Business Conduct and Compliance alias before making the payment. If prior approval is not possible, you must report the payment within 48 hours of its occurrence to the Business Conduct and Compliance alias.

4. No facilitating payments, ever.

Do Not Make Facilitating Payments: A facilitating payment is a payment to secure or expedite a routine government action by an official. Do not make facilitating payments.

This policy is similar to Apple and Novartis. In contrast, Tesla might approve some facilitating payments.

5. Don’t hire princelings or others based on threats against the company.

Hiring Decisions Must Not Benefit Government Officials: Do not hire an official or someone suggested by, or related to, an official to help Microsoft obtain or keep business, or if the official offers to give a benefit to Microsoft or threatens to act in a way that harms Microsoft if the requested hiring decision is not taken. Always use Microsoft’s normal hiring process. Before hiring an official or a candidate suggested by an official, review and comply with the Procedure for Hiring Decisions Involving Government Officials.

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View more anti-corruption policy benchmarks here.

Here’s the full five-page anti-corruption policy:

Microsoft Anti-Corruption Policy - FCPA Blog

 

Click here to download the Microsoft anti-corruption policy

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