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Microsoft is committed to doing business with integrity and transparency. Microsoft prohibits bribes or offer of a bribe or kickback of any kind, including to Government Officials, or employees of government-owned or controlled companies, and in commercial transactions. Microsoft also prohibits soliciting or accepting a bribe or kickback. Policy applies to our employees, partners, suppliers, consultants, lobbyists or other third parties acting on behalf of Microsoft

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Compliance with all applicable Anti-Corruption Laws Facilitating payments (small payment to expedite Government action) are prohibited Unless authorized and approved by Microsoft in writing, providing travel for Government officials on Microsoft’s behalf is prohibited Government Tenders—Orders should be placed with Microsoft after the partner who places the order has won the tender Accurate and timely response to Microsoft vetting procedures Adequate due diligence prior to hiring sub-contractors Report any concerns about compliance violations or applicable laws

Record all transactions in reasonable detail No undisclosed or unrecorded funds or payments Prohibit false, misleading, incomplete, inaccurate or artificial entries Do not use personal funds to accomplish what is prohibited by Microsoft policy Co-operate with Microsoft’s reasonable requests to review records

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