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Microsoft Finance Code of Professional Conduct

The Microsoft Code of Professional Conduct is put in place to reinforce the mission of promoting professional conduct in the practice of financial management worldwide. All employees are expected to adhere to this code or the results may include disciplinary action or termination of employment.

The code asks that employees avoid conflicts of interest between personal and professional relationships, provide stakeholders with accurate and timely information, adhere to the rules set by the federal and state governments, act responsibly with sound judgment, respect confidentiality within the work environment, share information and act professionally in regards to Microsoft’s stakeholders, promote ethical behavior at work and in the community, use company resources responsibly, and avoid interference in the auditing process or any form of manipulation directed at the accounting or finance departments.

All Microsoft employees are expected to report any suspected violations of the Code of Professional Conduct, the Standards of Business Conduct, or any other professional policies and guidelines to a member of the management team, the Human Resources department, an LCA contact, the Director of Compliance, or the Business Conduct Line 24-hour number.

There is a section of the employee handbook that outlines standard procedures for reporting such concerns. If there is reason

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to suspect questionable activity in the accounting or auditing sectors then either the Director of Compliance should be notified, an anonymous email sent, or the Business Conduct Line should be called. Microsoft will try to keep the confidentiality of anyone reporting suspicious behavior to the company.

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