Preventing modern slavery and human trafficking in our operations and supply chains requires the

engagement of key business sectors where we have determined there is potential risk of human

trafficking and forced labor. The United States Department of Labor’s List of Goods Produced with Child

Labor or Forced Labor has identified the manufacture of electronics as posing a threat for child and forced labor. Therefore, our programs to minimize the danger of modern slavery and human trafficking primarily focus on Microsoft business units associated with the manufacture of Microsoft devices and hardware used in Microsoft data centers - particularly in high-risk countries where there are potentially vulnerable workers. p. 8

The Devices Responsible Sourcing (RS) Team implements a management system approach aligned to the OECD Due Diligence Guidance for Responsible Business Conduct that focuses suppliers on managing and mitigating risks in their operations and sub-tiers to address modern slavery and human trafficking risks. Data from global risk assessments and audit programs enable the RS Team to understand possible modern slavery and human trafficking risks in the Devices’ supply chain and develop strategies and programs to address risks. New and directly contracted strategic Devices’ hardware and packaging suppliers undergo initial risk and capability assessments and audits to assess their conformance to the SEA requirements. p. 8