Suppliers:

"During onboarding, suppliers received training on the Microsoft Supplier Code of Conduct, Supplier SEA Manual, RSRM Policy and SEA Specification training. Microsoft required suppliers to put a corrective action plan in place to address non- conformances found during the Initial Capability Audit before production began. If a factory was unable to meet our requirements, they were restricted from doing business with us until all nonconformances were corrected or remedied."

"In FY21, we leveraged our SEA Academy online platform to scale training across our global supply chain. All final assembly manufacturers and strategic component suppliers completed online training on Microsoft human trafficking and forced labor requirements. By the end of FY21, 206 suppliers had completed SEA requirement training, resulting in a 27 percent increase in knowledge according to pre- and – post-training assessment. We also engaged with the Responsible Labor Initiative (RLI) to deliver a practical training on a Responsible Recruitment toolkit to selected suppliers in countries with forced labor and recruitment fee risks associated with foreign migrant workers."

Procurement/Purchasing: "Internally, our Strategic Sourcing team and Factory Management teams received training on human trafficking and forced labor requirements, enabling them to incorporate conformance requirements into procurement decisions and to detect and address risks. Detailed requirements were shared to build Microsoft employee awareness regarding the potential risks of forced labor and human trafficking in Microsoft supply chains and the actions that must be taken to minimize such risks."

No mention of specific training for leadership nor HR.

pg. 6

“Microsoft Procurement is responsible for the Microsoft Supplier Code of Conduct (SCoC) and managing annual supplier SCoC training compliance.”

Pg. 10

“All suppliers must inform employees, agents, sub-agencies, recruiters, contractors, and subcontractors about supplier’s policies that prohibit human trafficking, prison labor, forced labor, and other forms of slavery and provide training and programs to promote awareness, risk identification, employee reporting, corrective action, and potential penalties for violations.”

Pg. 17

“During onboarding, suppliers received training on the Microsoft Supplier Code of Conduct, Supplier SEA Manual, RSRM Policy and SEA Specification training.”

Pg. 21

“All final assembly manufacturers and strategic component suppliers completed online training on Microsoft human trafficking and forced labor requirements.”

“Internally, our Strategic Sourcing team and Factory Management teams received training on human trafficking and forced labor requirements, enabling them to incorporate conformance requirements into procurement decisions and to detect and address risks.”