Rules of procedure for Microsoft's complaint mechanism
A. Preamble
Microsoft Corporation (hereinafter referred to as Microsoft) is committed to respecting globally recognized human rights both in its own business activities and through responsible supply chain management. The company and its subsidiaries comply with provisions of the Supply Chain Due Diligence Act (LkSG) and related guidance from the Federal Office for Economic Affairs and Export Control regarding human rights and environmental due diligence obligations and monitor their continuous compliance. A central component of these due diligence obligations is the establishment of a functioning reporting system that makes it possible to report potential human rights and environmental hazards or violations. Microsoft has implemented this complaint procedure within the Microsoft Integrity Portal and related business processes, which serve as the designated intake platform for
LkSG-related reports.
These Rules of Procedure explain the basic characteristics of the reporting system,
describe the accessibility of and options to reach the procedure, and define the corresponding responsibilities. In addition, they show how received reports are processed and what steps the complaints procedure includes. For Microsoft
Deutschland GmbH and its subsidiaries, it is important to communicate this information in a clear and understandable way to help advance the meaningful transparency regarding the entire process.
B. Scope
Microsoft's Complaint Mechanism allows anyone, including but not limited to
Microsoft employees and individuals or groups impacted by Microsoft's supply chain operations, to submit concerns related to human rights and the environment to
Microsoft. The complaints procedure is available for any type of concern, including suspected or actual violations of law, Microsoft codes of conduct (e.g., the Supplier
Code of Conduct), or Microsoft policies.
C. Target group and the complaints procedure
Anyone can make reports, regardless of geographic location. The Microsoft Integrity
Portal is available in multiple languages.
D. Responsibility for processing
The Microsoft Integrity Portal is offered via EthicsPoint, a comprehensive and confidential reporting tool created by NAVEX to assist companies like Microsoft in addressing alleged misconduct.
Reports are entered directly on the EthicsPoint secure server to prevent any possible breach in security. EthicsPoint makes these reports available only to specific individuals within Microsoft who are charged with evaluating the report, based on the type of violation and location of the incident. These individuals are selected to ensure
impartiality and independence in the handling of reports and are not bound by technical instructions regarding the assessment and processing of complaints.
Each of these report recipients has had training in keeping these reports in the
