[company name] Anti-Bribery Statement

[company name] upholds our commitment to ethical business practices, including by prohibiting bribery and corruption. As Transparency International explains, the costs of corruption are

political, by posing a major obstacle to democracy and the rule of law

economic, by depleting national wealth

social, by undermining people’s trust in political society, institutions, and leaders

environmental, by facilitating non-enforcement of environmental laws and regulations.

[company name] policies prohibiting bribery

[company name] makes our anti-bribery commitment clear in a number of company policies. As part of the Microsoft family, [company name] is also committed to Microsoft's Anti-Corruption Policy, which applies to all [company name] employees and contractors, in addition to the policies described here.

[company name]'s Code of Ethics prohibits employees and contractors from engaging in or contributing to bribery or corruption, and establishes record-keeping requirements:

You must never pay, offer to pay, promise to pay, induce, accept, or authorize payment of anything else of value, to anyone—including to anyone in a position of power or authority, such as government officials, or in commercial transactions—in order to obtain or keep business, or secure any other improper advantage for [company name]. You also must not solicit or accept a bribe, kickback, or any other improper cash payment. ... [[company name]employees] are required to keep accurate and fair records of all transactions involving any expense made on [company name]’s behalf—for example, by keeping receipts and providing accurate descriptions of your expenses—or any other transaction involving the disposal or transfer of [company name] assets. Such actions are required by the [governing law], the [governing law #2], and anti-bribery laws of other jurisdictions in which [company name] does business and are also simply the right thing to do.

[company name]'s Code of Ethics elaborates on certain situations, including gifts, travel, and entertainment; facilitating payments; charitable donations; jobs; and working with representatives, as well as on who is considered a government official.

[company name]'s Standards of Conduct prohibit:

Bribing government officials or other individuals to gain an unfair advantage, and taking bribes from anyone.

[company name]’s Gifts and Entertainment Policy explains that bribery is not permitted in connection with travel or entertainment, and provides examples to illustrate improper conduct. The policy describes proper and improper gifts, travel, and entertainment expenses; company processes for gift-giving by [company name]’s directors, officers, employees, and agents and requirements for record-keeping, penalties; and reporting of violations. It includes clear monetary thresholds for gifts along with annual limitations, with limited exceptions for gifts approved by appropriate management. The policy is clear and easily accessible to [company name] employees and contractors.

Training for our employees

[company name] employees are required to participate in training on corruption, including bribery. We also provide additional training for particularly relevant people and teams, such as our sales team. The training explains relevant elements of the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act of 2010. For example,

definition and structural effects of corruption

who is covered, including

public officials or others in a position of power

third parties

what kind of activity is covered, including

cash, gifts, travel, and entertainment

facilitation payments

charitable contributions and sponsorship

for what purpose, including

intent

improper advantage or influence

due diligence and red flags

record-keeping requirements

In addition, the training covers [company name]’s internal policies related to anti-corruption and bribery, including our non-retaliation (whistleblower) policy.

While the U.S. FCPA is focused on interactions with government officials, the U.K. Bribery Act is broader and extends to bribing anyone, regardless of whether they are a government official. Both laws can extend to [company name]’s actions elsewhere on the globe. [company name]’s policies prohibit bribing anyone, anywhere in the world.

Engaging our Partners

[company name]’s standard resale agreements with [company name partners] include mandatory anti-corruption clauses. Going forward, [company name] now requires our [company name partners] to commit to complying with this Anti-Corruption Statement.

Going forward, [company name]’s vendor contracts now require a commitment to comply with [supplier code of conduct link] or [anti-corruption statement link].