Anti-Corruption Policy for Microsoft Representatives

This Anti Corruption Policy for Microsoft Representatives (“Policy”) prohibits the corruption of government officials, which means paying money or giving something of value to a government official to obtain an improper benefit. This Policy similarly prohibits the payment of bribes or kickbacks in commercial transactions regardless of whether any government officials are involved. Corruption is forbidden by the laws in almost every jurisdiction of the world. This Policy also prohibits money laundering, which is the process of concealing funds that have been illegally obtained.

Microsoft Corporation, and all of its subsidiaries and joint ventures worldwide (“Microsoft”), requires its channel partners (for example, resellers, software advisors, original equipment manufacturers, and distributors), suppliers, consultants, lobbyists, and other third-party representatives (collectively, “Microsoft Representatives”) to comply with this Policy.

Microsoft Representatives acting on behalf of Microsoft can expose Microsoft to liability under anti-corruption and anti–money-laundering laws, including the United States Foreign Corrupt Practices Act (“FCPA”). Corruption promotes poverty, hunger, disease, and crime, and keeps societies and individuals from reaching their full potential. Corruption is one of the leading obstacles to economic and social development. Microsoft is committed to observing the standards of conduct set forth in the FCPA and the anti-corruption and anti–money-laundering laws of the countries in which it operates. Microsoft is also committed to taking reasonable steps to ensure that Microsoft Representatives comply with these standards of conduct and laws in its dealings with or on behalf of Microsoft.

1. Compliance with Anti-Corruption Laws: Each Microsoft Representative shall conduct itself with high ethical standards and comply with all applicable anti-corruption laws, including the FCPA. No Microsoft Representative shall, directly or indirectly, offer or pay anything of value (including but not limited to gifts, travel, entertainment expenses, and charitable donations) to any official or employee of any government, government agency, political party, or public international organization, or any candidate for political office, to (i) improperly influence any act or decision of such official, employee, or candidate for the purpose of promoting the business interests of Microsoft in any respect, or (ii) otherwise improperly promote the business interests of Microsoft in any respect. Note that Microsoft Policy specifically prohibits facilitating payments, also known as “grease” or “speed” payments, which are small payments to secure or expedite a routine government action by a government official. 2. Trustworthy Representatives. Microsoft will conduct appropriate due diligence or “vetting” of Microsoft Representatives to determine that the Representative has a reputation for integrity and will not pose undue risk of noncompliance with this Policy. As part of this process, Microsoft will ask the Microsoft Representative to respond to a questionnaire and, if appropriate, provide additional information that may be necessary in the reasonable judgment of Microsoft. Microsoft appreciates the understanding and cooperation of each Microsoft Representative in this regard.

3. Anti–Money Laundering: No Microsoft Representative shall use its relationship with Microsoft to disguise or attempt to disguise the sources of illegally obtained funds.

4. No Retaliation: Microsoft Representatives will not retaliate against anyone who has, in good faith, reported a possible violation of this Policy or refused to participate in activities that violate this Policy.

5. Enforcement: Microsoft will enforce this Policy in accordance with the terms of its contracts with Microsoft Representatives.

Reporting

Microsoft Representatives may report concerns with conduct covered by this Policy to the Microsoft Office of Legal Compliance through the following alternatives:

By the Microsoft Business Conduct Hotline:

. (877) 320-MSFT within the United States, or if calling from outside the United States, you may make a collect call to the Hotline by accessing an international operator and asking to place a collect call to (704) 540-0139.

. The Business Conduct Line is a dedicated, toll-free phone line that is available to you 24 hours a day, 7 days a week, 365 days a year.

By Microsoft e-mail or Web allegation tool: [email protected] or www.MicrosoftIntegrity.com

By mail or fax: Send a letter to the Director of Compliance at Microsoft Corporation at the following address:

Office of Legal Compliance One Microsoft Way Redmond, WA 98052

Send a fax to the following number: (425) 705-2985

Further information about contacting Microsoft with a compliance question or concern can be found in the Microsoft Standards of Business Conduct.