We hold ourselves to very high ethical standards, and we want our representatives, who include the partners, vendors, consultants, and other firms that operate on our behalf, to match the same standards that we have established for ourselves. When we provide value to our representatives and don’t expect them to do anything that we wouldn’t do ourselves, this helps build trust between us and our representatives.
The representatives of Routeget Technologies are subjected to risk-based due diligence and screening by our company. The process of vetting helps identify representatives who pose a higher risk, and it requires that certain representatives be subject to enhanced vetting so that we can decide whether or not it will be possible for those representatives to begin or renew a business relationship with our company or any of its subsidiaries. Identifying representatives that pose a greater threat to the company is currently accomplished through the application of data analytics. Specifically, an algorithm is used to compute a risk score for each representative based on internal and external data attributes. In 2019, we started making use of these data analytics in order to perform due diligence on a few representatives, and we are also continuing to work on extending this one-of-a-kind program.
Written agreements between Routeget and our representatives include a provision that requires full compliance with all relevant anti-money laundering and anti-corruption legislation. It is against the law to engage in any sort of corruption, including taking bribes or giving kickbacks of any kind. We make it mandatory for our channel partners to offer discounts to the government customers who buy from them, and we inform these government customers about the savings that are offered for their benefit. To that end, we want to do everything we can to make sure that no discount is ever abused in any way. This procedure is one that we are always working to perfect and perfect further so that our clients may take full advantage of any discounts that we may provide. In addition, the criteria for the approved use of additional resellers as well as the prerequisites for legitimate end customer purchase commitments are outlined in our agreements.
When conducting business with or on behalf of Routeget, we anticipate that our suppliers will make a commitment to ensuring that their operations are conducted in full accordance with all applicable laws and regulations, as well as to adhering to the Supplier Code of Conduct. The training of any and all workers that operate on Routeget’s behalf is the responsibility of the suppliers. For our suppliers, mandatory training on the Supplier Code of Conduct is provided by our company.
While doing business with Microsoft customers, it is our expectation that our partners will embrace, continually improve, and uphold Routeget’s ethical and integrity standards. Additionally, we expect our partners to conduct their operations in full compliance with all applicable laws and regulations. Partners are accountable for ensuring that all of their staff members who perform work on behalf of Microsoft are properly trained and comply with the Partner Code of Conduct.
This anti-corruption policy is one that Microsoft Corporation and all of its worldwide subsidiaries and joint ventures (collectively referred to as “Routeget”) require their channel partners (such as resellers, software advisors, original equipment manufacturers, and distributors), suppliers, vendors, consultants, lobbyists, and any other third-party representatives (collectively referred to as “Routeget Representatives”) to adhere to.
Routeget will not stand for anybody who has, in good faith, reported a probable violation of this Policy or who has refused to engage in actions that violate this Policy being subjected to reprisal in any way.
The Routeget representatives are subjected to the proper levels of due diligence, sometimes known as “vetting.” The screening processes of Routeget must be followed by representatives at all times. Routeget is grateful to representatives for their cooperation, understanding, and provision of information and replies that are correct and provided in a timely manner in relation to Routeget’s screening processes.
Routeget may, in addition to its rights and remedies under applicable agreements, refer any representative who violates this policy to US or foreign authorities for criminal prosecution or other enforcement action, or it may bring suit for damages. This is in addition to Routeget’s rights and remedies under applicable agreements.
It is strictly forbidden for representatives of Routeget to foot the bill for government officials’ travel, housing, gifts, hospitality, or charity donations on behalf of Routeget. It is against the rules for representatives to use monies from Routeget to cover the costs of travel, housing, gifts, hospitality, or charity donations made on behalf of government officials.
A minor payment that is made to a government official in order to obtain or accelerate a routine activity that does not fall under their discretion is referred to as a “facilitating payment.” Any kind of bribery, including the facilitation of payments, is strictly forbidden on Routeget.
The information that representatives are required to record in their business books, records, and accounts, including payments and other forms of remuneration, must be accurate, recorded in a timely manner, and contain a reasonable amount of detail. It is against the rules to keep any accounts secret or unrecorded, regardless of the reason. It is against the rules to make entries in the books and records that are dishonest, deceptive, incomplete, incorrect, or contrived. It is not permissible to utilize personal cash in any way to circumvent the other restrictions imposed by this policy or any other rules of Routeget.
No representative of Routeget is permitted to utilize their affiliation with the company in order to conceal or attempt to conceal the origins of monies that have been unlawfully obtained.
Routeget representatives have been given the instruction to report any concerns they may have regarding the possible violation of this policy or relevant laws to either the legal department or the officer in charge of ethics and compliance. Concerns of this nature should also be communicated to Routeget by the representatives.
All of the following are included under the umbrella term “Government Official”: any employee of a government entity or subdivision, including elected officials; (ii) any private person acting on behalf of a government entity, even if just temporarily; (iii) officers and employees of companies that are owned or controlled by the government; (iv) candidates for political office; (v) officials of political parties; and (vi) officers, employees, and representatives of public international organizations, such as the Reserve Bank of India, World Bank and the United Nations, etc. The representatives are also made aware of the fact that in some nations and in some fields, a person who appears to work for a private firm might be deemed a government official.
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