Microsoft Corp

Lobbying Governance

AI Extracted Evidence Snippet Source

Environmental, Social, and Public Policy (ESPP) Committee charter (https://www.microsoft.com/en-us/corporate-responsibility/reporting-governance)—role of the committee in assisting our Board of Directors with overseeing Microsoft sustainability policies and programs.

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We understand that public policies will play a critical role, both in creating signals to spur the economic and social transition required to address climate change and in building the foundations of markets to develop and deliver innovative goods, services, and skills to achieve that transition. Microsoft engages in public policy advocacy directly, as well as through our membership in trade associations. As we make progress toward sustainability commitments, we also evaluate how our climate goals are aligned with the advocacy efforts of the trade associations we are members of. This report provides an overview of positions on eleven key climate policies held by eight organizations that are active in federal climate policy: Advanced Energy United, Business Roundtable, Center for Climate and Energy Solutions, Clean Energy Buyers Association, Ceres, Climate Leadership Council, Information Technology Industry Council, and the U.S. Chamber of Commerce. The purpose of this report is to help us evaluate how well these trade associations align with our own sustainability goals and values, and to identify potential areas of collaboration or misalignment. Where there is misalignment, we will redouble efforts to engage with the trade association to drive closer alignment in their advocacy for a more sustainable future.

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Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Our participation in the political process is transparent and based on our principles. We are pleased that Microsoft ranks in the first tier of rating given by the CPA-Zicklin Index of Corporate Political Accountability and Disclosure for our policies that ensure the accountability and transparency of our public policy engagement. Our Senior Director of Global Sustainability Policy coordinates across business groups and directly with government affairs teams around the world to ensure consistency between our advocacy work and our climate change and sustainability strategy. The responsibilities of the Environmental, Social, and Public Policy Committee of the Microsoft Board of Directors include reviewing and providing guidance to the Board and management about key environmental and social matters such as climate change and environmental sustainability. We articulate our public policy position on climate change in our January 2020 carbon negative statement. Microsoft's "Principles and Policies for Guiding Participation in the Public Policy Process† in the US includes principles on oversight of trade association memberships. Those policies note, "We review these memberships annually to assess their business value and alignment with Microsoft's overall public policy agenda. We work with many of these groups on narrowly-tailored technology policy issues relevant to specific business objectives and it is unrealistic to expect any group's agenda to align with ours in all policy areas. Therefore our engagement with a particular group does not and should not imply our endorsement of all the policy positions those groups have taken. However, we will not support groups that spend an abundance of their time working against our direct business interests and public policy agenda.† When we have policy differences, we have issued statements that clarify that the trade association is not representing Microsoft on that specific policy.

CDP Questionnaire Response 2022

Microsoft's Lobbying Alignment Report

For all the uncertainty in the world, one thing is clear: People and organizations in every industry are increasingly looking to digital technology to overcome today's challenges and emerge stronger. Microsoft's leaders have articulated the perspective that when your technology changes the world, you bear a responsibility to help address the world you have helped create ("Tools and Weapons: The Promise and Peril of the Digital Age," by Brad Smith, Vice Chair and President of Microsoft, and Carol Ann Browne, General Manager and Chief of Staff) Therefore, it is crucial that as we forge ahead with digital innovation, we do so with a keen sense of responsibility and a commitment to actively nurture the positive outcomes of technological advancements.

At Microsoft, we recognize the potential of technology to empower individuals and organizations to create a better world. Artificial intelligence (AI), among other transformative tools, has the capacity to bring about significant positive changes in various aspects of society. From AI-driven solutions that advance healthcare outcomes to renewable energy technologies addressing climate change, these innovations hold promise in solving complex challenges and improving lives. However, to help these technologies meet their potential while ensuring responsible and ethical development and deployment, it is imperative for companies, scholars, and governments to come together and collaborate openly and honestly on establishing robust frameworks and guidelines that prioritize the well-being of individuals and society.

Microsoft actively engages with governments, policy makers, and civil society partners across the world to advocate for the important issues impacting our business, our customers, our partners, the communities in which we operate, and the world in which we all live. Through close collaboration with stakeholders at various levels, we seek to shape public policy outcomes that not only support responsible innovation but also foster trust in technology.

We have created this report to provide visibility into our policy engagement and partnerships. We view this report as a means to uphold our responsibility to stakeholders and the wider community, while also serving as a mechanism for selfreflection and accountability. We are committed to open and transparent discussions that create a sustainable future, protect fundamental rights, and promote trust in technology. To provide transparency on where we stand, here are the key policy positions we advocate for and some examples of specific legislation where we've taken positions.

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Lobbying Advocacy

Creating a More Sustainable Future

Microsoft has a longstanding history of environmental sustainability action and advocacy. When we announced our commitment to become carbon negative by 2030, we pledged to use our voice to support the policies that we believe will have the greatest impact on combatting the negative effects of climate change. Meaningful climate action requires an enduring commitment from both government and business, with the private sector playing an increasingly important role in the transition from pledges to progress. To continuously support communities and companies in their efforts to achieve their climate pledges, we actively lobby for accelerated federal and state policy action in this space.

Advocating for legislative climate and energy investments: In the United States, we

advocated for climate and energy investments as part of the recent US infrastructure

and climate laws, including the Infrastructure Investment and Jobs Act and the

Inflation Reduction Act. In addition, we shared our support for a robust and consistent framework for climate disclosure requirements by the US Securities and Exchange Commission and provided comments to the requests for information climate disclosure for US federal procurement. Microsoft continued to encourage tree planting and reforestation efforts through our support of the Trillion Trees Act, as well as efforts to improve the health of old-growth forests by supporting the Save Our Sequoias Act. At the state level, we supported legislative and regulatory efforts to accelerate the clean energy transition by encouraging the integration of zero-emission generation and improving the resilience of the electric grid. At the state level, we lent our support to legislative and regulatory endeavors aimed at accelerating the clean energy transition, emphasizing the integration of zero-emission generation and bolstering the resilience of the electric grid. Notably, we actively participated in a coalition opposing the Virginia Electric Utility Regulation Act, which sought to limit retail choice of energy sources, and ultimately, we contributed to reaching a compromise that protected retail choice.

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Supporting carbon reporting, reduction, and removal legislative efforts: To avoid

the worst impacts of climate change, the world needs to keep increases in global temperatures well below 2°C and reach net-zero emissions by 2050. Governments will need to put in place additional policies that provide clear and consistent signals for reducing and removing carbon emissions across sectors and regions, such as carbon pricing mechanisms, emissions standards, and regulations that incentivize and encourage low-carbon innovation and technology adoption, if they are to achieve net-zero emissions by mid-century. At Microsoft, we believe that these policies should also recognize the potential for digital technologies, including artificial intelligence, data analytics, cloud computing, and internet of things, to enable innovation and inclusion in the transition to a low-carbon economy. Furthermore, policies should aim to expand market opportunities for all stakeholders, including those who are most vulnerable to climate impacts.

Accelerating the transition to clean electricity generation: Reliable and affordable

electricity has never been more crucial as the world moves to a net-zero carbon emissions economy. For the electricity sector carbon emissions to decline overall, growth in clean electricity generation must significantly exceed growth in electricity demand. Microsoft will support policies that expand, robust, reliable, and carbon-free grid by: (1) accelerating the transition to clean electricity generation; (2) modernizing and improving grid infrastructure; and (3) encouraging an equitable energy future. Microsoft advocates for policies that promote a diverse mix of zero-carbon energy sources for a reliable, resilient, and flexible grid. This includes wind, solar, hydro, nuclear, and green hydrogen power, as well as energy storage technology to dispatch zero-carbon electricity on demand. We recognize that the most appropriate policy design may differ between countries and regions, but we support measures such as regulatory caps, clean energy standards, subsidies, and public procurement that promote a transition towards clean energy.

AI for Earth: AI for Earth has helped empower individuals and organizations to develop innovative solutions to the way we monitor, model, and ultimately manage Earth's natural systems through grants, technology, and access to data. Since its inception, the program supported over 950 projects located all around the world and enabled more than 50 strategic partners with Azure. Following the announcement of Microsoft's ecosystems commitments in 2020, the AI for Earth program has evolved to building the Planetary Computer. The Planetary Computer combines a multi-petabyte catalog of global environmental data with intuitive APIs, a flexible scientific environment that allows users to answer global questions about that data, and applications that put those answers in the hands of conservation stakeholders. In line with our responsible AI priorities, we actively engage in legislative lobbying efforts to shape policies that promote responsible and ethical AI practices in the realm of environmental conservation. By leveraging our expertise and the insights gained from the AI for Earth program, we advocate for the integration of sustainability-focused guidelines within AI legislation, emphasizing the importance of harnessing the power of artificial intelligence to address pressing environmental challenges and pave the way for a more sustainable future.

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Privacy & Trust

At Microsoft, we believe privacy is a fundamental human right that requires a commitment to provide robust data protection for every individual and organization. We live up to this commitment by providing products, information, and controls that allow you to choose how your personal data is collected and used. Privacy laws are essential to earning the public's trust in technology and enabling businesses to innovate with certainty and confidence. Furthermore, it is crucial for policy solutions to ensure an equitable playing field between federal and state privacy regulations, while upholding the strength and integrity of existing state privacy laws. As such, Microsoft is committed to partnering with lawmakers to ensure that any new privacy law provides rigorous protection for individuals and clear guardrails for companies regarding their collection, disclosure, and use of personal data.

Federal comprehensive privacy legislation: We have been advocating for

comprehensive data privacy at the federal level since 2005. Despite a growing concern and calls for regulation, the Congress has yet to pass a new privacy law. However, over the past few years we have seen more bipartisan interest at the federal level. In the last session of Congress, new legislation known as the American Data Privacy and Protection Act (ADPPA) passed out of the House Energy and Commerce Committee by a vote of 53-2 and was the first federal comprehensive privacy bill to pass a committee markup. It would have established requirements for consumer rights, data minimization, individual ownership, children protections, and automated decision making. We supported many of the concepts in the bill and continue to work closely with the authors and staff to get to a position of support.

Comprehensive privacy legislation in the states: This has been another very active

year on state privacy legislation. We have been tracking 128 privacy bills, 50 of which constitute comprehensive privacy bills, and have been actively lobbying and testifying in several states to support privacy legislation. That includes the states of Indiana (SB 5), Tennessee (SB 73/HB1181), and Montana (SB 384), which became the seventh, eighth and ninth states respectively to enact comprehensive privacy laws. We are largely supportive of states working to protect privacy in the absence of more comprehensive federal protections and want to ensure state legislation provides strong privacy protections. For instance, we did not support Iowa (SF 262) (which became the sixth privacy law) in its final form, as it contained many loopholes, despite our many efforts to work closely with legislators to strengthen the bill. In several more states, we continue to support active privacy bills, including Texas, where the Texas House and Senate have passed comprehensive privacy bills (TX HB 4) (likely sending the issue to a conference committee), Oregon (OR SB 619), New York (SB 365), Rhode Island (SB 754), and Delaware (HB 154). In Hawaii (SB 974), New Hampshire (SB 255) (where we testified twice), New Jersey (SB 332), and Oklahoma (OR SB 619), comprehensive privacy legislation passed through one legislative chamber. Finally, Florida's legislature passed a comprehensive privacy bill (SB 262) on the last day of its session, a bill that Gov DeSantis supported and is expected to sign.

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As part of our work on comprehensive privacy, we worked actively with lawmakers and others in the state of Washington, which passed a consumer health data privacy law—a law that incorporates substantial parts of the Washington Privacy Act (a comprehensive privacy bill that we helped design but that the Washington legislature narrowly failed to pass for four straight sessions) and that could form the basis for a comprehensive law in the future.

We continue to work with other legislators around the country on health data privacy bills. All told, five more states enacted or will soon enact comprehensive privacy laws this year (which would bring the total number of states with comprehensive privacy laws to ten) with several more possible. The vast majority of these bills are largely based upon the framework established by the Washington Privacy Act.

Right to Repair: We continue to work with advocates, industry, and policymakers on reasonable and meaningful right to repair legislation, which would provide consumers and independent repair providers with some ability (within reason) to repair devices in a safe, reliable, and sustainable manner. We helped lawmakers advance the first right to repair law in New York, (The Digital Fair Repair Act) and worked in particular to ensure that while the bill would provide consumers and independent repair providers with new rights, it would also not conflict with our current business models and would not unfairly burden manufacturers. We also worked intensively with US PIRG, legislators, and industry to support a bill in Washington state; the bill passed out of the House but ultimately failed in the Senate. However, the Minnesota legislature has passed a modified version of that bill, which will likely make it the second state to pass a right to repair law. California and Maine both have active right to repair legislation that we are tracking closely. All told, we have been tracking 28 right to repair bills across the states.

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Open AI: At Microsoft, we take privacy and trust in AI seriously. Through our various initiatives, we actively work towards shaping legislation that focuses on these crucial aspects. For instance, our Azure OpenAI Service is designed to process data responsibly, enabling us to deliver high-quality service while monitoring for abusive use and continuously improving our Responsible AI systems. We want you to feel confident in your control over your data, which is why we make contractual commitments to ensure that your data belongs to you, and we will never use it without your agreement. Additionally, we are committed to being principled and transparent in how we handle data requests. But our efforts don't stop there. We are dedicated to making a positive impact through legislative lobbying. By advocating for robust privacy protections and emphasizing the significance of user control over data, we strive to influence AI legislation that prioritizes responsible data practices and fosters trust in AI systems. Our goal is to collaborate with policymakers and shape regulations that prioritize privacy rights and establish clear guidelines for data usage. In doing so, we aim to create an environment where individuals and organizations can confidently leverage the benefits of AI while safeguarding their privacy.

Fundamental Rights

As we pursue our mission to empower every person and every organization on the planet to achieve more, we are guided by our unwavering commitment to inclusive growth. This means ensuring that every individual has equal access to the opportunities and resources they need to thrive. We believe that policymakers have a critical role to play in creating a more inclusive society. As part of our unwavering commitment to inclusive growth, we actively lobby for policies that promote closing the accessibility divide, increasing broadband access, and providing job training to underrepresented communities, while also investing in AI-powered tools and other resources to create a more level playing field and give everyone a chance to succeed in the digital economy.

Working to close the disability divide through accessible solutions: When

governments try to solve complex challenges with obsolete technologies, people with disabilities can be left behind. Microsoft is an advocate for the use of leading-edge technology like Artificial Intelligence (AI) to solve accessibility challenges and create innovative, accessible solutions for citizens. To ensure that people with disabilities are not left behind, governments should adopt policies that support the use of AI and other advanced technologies in solving accessibility challenges. Additionally, policymakers should encourage the development of open standards and interoperable systems to ensure that accessibility solutions are widely available and can work seamlessly with different devices and platforms. We have an active role to pressure governments to introduce and pass legislation that ensures that people with disabilities have equal access to information and services, thus creating a more inclusive society.

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Ensuring the Americans behind American innovation are supported by aligning key federal programs to focus on retraining and new job-relevant skills

acquisition. This includes promoting investments in education and training programs that equip individuals with the skills needed to succeed in the digital economy and closing the skills gap to ensure all individuals have access to quality employment opportunities. As a part of our commitment in this space, we openly support the

Transformation to Competitive Integrated Employment Act (S.533). This bill seeks

to improve employment opportunities for individuals with disabilities by providing grants to states and eligible entities to promote competitive integrated employment and community participation. It also prohibits the issuance of new subminimum wage certificates for disabled individuals and gradually phases out existing certificates over four years, while providing technical assistance and support to employers undergoing this transition. Additionally, the bill mandates an evaluation of the impact of these transitions by a nonprofit entity contracted by the Department of Labor.

Ensuring broadband access for all Americans: Having broadband is essential for all of

us to participate in society's daily routines. Education, work, healthcare, entertainment, and other aspects of life often require some level of broadband access. Unfortunately, too many Americans are at a digital disadvantage lacking broadband connectivity and unable to participate fully in today's society. To address the challenge of access to affordable and reliable internet connectivity for consumers impacted by the cost of

broadband, Congress should make funding for the Affordable Connectivity

Program permanent, which offers discounts on internet service and devices to eligible households. Additionally, to ensure consumers have access to cloud-based services and content, policymakers should support the efforts of regulators to make the 6 GHz band available for a variety of unlicensed use, enabling technologies like Wi-Fi to connect multiple devices seamlessly. These policy recommendations will help bridge the digital divide and ensure equitable access to broadband connectivity.

Support clean slate and expungement reform: Microsoft joined the Business

Roundtable's Second Chance Coalition, a cross-sector coalition comprised of large private-sector firms committed to fair chance hiring, which formed to share best practices, ask questions about implementation, and learn from each other. In addition, we've engaged in public policy advocacy to support clean slate and expungement legislation in states across the country – including New York, Georgia, and California.

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Microsoft has been active in combatting legislation that would lead to discrimination while supporting legislation that would expand protections for LGBTQI individuals. We prioritize the safety, dignity, and respect of our employees and their families. We strongly believe that discrimination has negative consequences for business. It creates divisions in communities, limits opportunities, stifles innovation, hampers recruitment and retention of top talent, and diminishes the dynamic and creative potential of the business community. Microsoft also advocates in states where Microsoft's voice could have impact, and our efforts have helped change the course of anti-LGBTQI legislation. We will continue to work closely with our partner organizations and other businesses to advocate against discriminatory bills.

Trade Associations

Microsoft is a member of various industry and trade groups that represent both the tech industry and the business community at large to bring about consensus on broad policy issues that can impact Microsoft's business objectives. Our support of these organizations is evaluated annually by the company's U.S. Government Relations leaders based on these organizations' expertise in policy and advocacy and support of key issues of importance to Microsoft.

Four of our significant 501c6 trade association memberships are with the U.S. Chamber of Commerce (Chamber), the ITIA, the Business Roundtable (BRT), and the Software Alliance (BSA). We work closely and are proud of our collaboration with each of these trade associations on core issues of great importance to Microsoft's business and our stakeholders.

Microsoft's participation as a member of these various industry and trade groups comes with the understanding that we may not always agree with each position taken by the larger organization and/or other members. Some misalignment is an unavoidable consequence of any collective endeavor. Nevertheless, we monitor where and to what extent our trade associations are misaligned with the company on such issues. Where possible, we will advocate for the trade association to come into alignment, but if an organization's misalignment is egregious, and the membership benefits to Microsoft and its stakeholders are outweighed by the misalignments, we will reduce or end our involvement with the organization.

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The following sections outline Microsoft's position as well as the positions of these three trade associations across the key public policy for Microsoft explored earlier in this report. The report also compares Microsoft's and the trade associations' positions and describes the degree of alignment or misalignment. Please note that while we are focusing on these three associations, this list is not exhaustive of all our trade association partnerships. Similarly, the three key areas discussed while are core to Microsoft's business, are not inclusive to all policy priorities of the company.

Microsoft and the U.S. Chamber of Commerce

The policy goals of Microsoft and the U.S. Chamber of Commerce are generally in alignment across the key areas reviewed earlier in this report. Microsoft's participation in the Chamber stems from its commitment to collaboration, driving positive change, and advocating for policies that promote a thriving business environment. To the extent differences exist in the company and trade association's respective positions, we remain committed to engaging in constructive dialogue to understand and address any areas of misalignment.

Sustainability: Like Microsoft, the U.S. Chamber of Commerce recognizes the importance of addressing sustainability challenges and acknowledges the need for mitigating environmental impacts. However, it should be noted that we do not always see eye to eye on climate policies.

From Microsoft's perspective, there has been a misalignment with the U.S. Chamber of Commerce regarding certain environmental policy issues. For example, Microsoft transparently reports across Scopes 1, 2, and 3 emissions and has been supportive of the SEC and FAR Council proposed rules requiring certain companies and government contractors to report emissions. Federal regulations provide a consistent framework that ensures all companies are held to the same standards, fostering a level playing field and enabling effective emissions reduction strategies. In addition, Microsoft is supportive of the Obama-era Clean Power Plan and is currently reviewing the EPA's new proposed rule regulating carbon emissions from fossil fuel generation sources under the Clean Air Act. The Chamber has come out in strong opposition of these rules. As a company committed to sustainability and combating climate change, we believe in the importance of transitioning to clean energy sources and reducing greenhouse gas emissions. The Chamber's stance on this issue did not align with our goals and efforts to drive meaningful environmental impact.

As Microsoft continues to prioritize sustainability and push for transformative change, we hope for increased collaboration and alignment with the Chamber to collectively address the urgent challenges posed by climate change. It is crucial that we work together to advance sustainable practices, support clean energy solutions, and establish robust regulations that promote accountability and transparency in emissions reporting.

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Privacy & Trust: Both Microsoft and the U.S. Chamber of Commerce support a unified national data privacy framework to protect consumer data, ensure transparency, and establish clear regulations. While they both prioritize privacy and consumer protection, they differ on the extent of policy and regulatory intervention required. Microsoft advocates for both state and comprehensive federal privacy law that sets consistent standards, streamlining compliance and safeguarding privacy rights for all individuals. In contrast, the Chamber expresses concerns about the complexities arising from varying state privacy laws and therefore favors a unified national framework to provide clarity for businesses operating across state lines.

While Microsoft has been proactive in advocating for robust privacy measures, the Chamber tends to take a more cautious approach. The Chamber has expressed concerns that excessive privacy regulations could impose burdensome compliance requirements on businesses, potentially hindering innovation, and economic growth. In contrast, we have been a vocal advocate for comprehensive privacy legislation that provides individuals with greater control over their personal data. Microsoft has championed the implementation of strong consumer protection measures, including transparent data practices, clear user consent mechanisms, and enhanced rights for individuals to access, correct, and delete their personal information. Microsoft has also been at the forefront of developing privacy-focused technologies and tools to empower individuals and organizations to protect their data.

Despite these differences, Microsoft and the Chamber share an interest in promoting innovation, economic growth, and responsible data practices. By engaging in constructive discussions, we hope to work towards finding a balanced approach that addresses privacy concerns while fostering a favorable business environment.

Fundamental Rights: Like Microsoft, the U.S. Chamber of Commerce recognizes the importance of closing the disability divide and promoting inclusivity in the workplace and society. While it is not one of their key policy pillars, the Chamber supports policies that promote equal employment opportunities for individuals with disabilities and encourage businesses to create accessible and inclusive workplaces. It recognizes the value of diverse talent and the benefits that come from fostering an inclusive workforce. Through its programs and resources, the Chamber provides guidance to businesses on how to accommodate and support employees with disabilities. We hope to continue working with the Chamber to foster discussions on supporting policies that address barriers to accessibility and equal opportunities can contribute to efforts in closing the disability divide.

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Microsoft and the Industry Technology Industry Council (ITI)

The policy goals of Microsoft and the Industry Technology Industry Council (ITI) are generally aligned. At the same time, we recognize the significance of maintaining clarity regarding our differing perspectives. It is important to identify and acknowledge these differences to facilitate meaningful discussions and ensure that policy decisions are well-informed and comprehensive. By openly addressing where misalignments exist, we can work towards finding innovative solutions that balance competing priorities and promote shared interests.

Sustainability: Microsoft engages with ITI on various committees that address emerging environmental laws and policies that impact the design, manufacture and sale of electronic devices, such as our Surface and Xbox devices. These issues include substance restrictions, energy efficiency, end-of-life management, ecolabeling, increased repairability, and green procurement. For the most part, Microsoft policies align with ITIC policies that promote laws and regulations that achieve environmental outcomes in ways that allow for sufficient transition periods and harmonized implementation worldwide. However, Microsoft has taken a different approach than ITI on the issue of "right to repair." Microsoft is actively working to develop legislation that meets the needs of producers as well as consumers. This approach was demonstrated in Washington State where Microsoft supported "right to repair" legislation whereas ITI opposed it. This misalignment in sustainability provides us with an important opportunity to engage in constructive discussions with ITI and seek a balanced approach to sustainability initiatives.

Privacy: Both Microsoft and ITI support comprehensive privacy legislation that provides a strong national standard, enhances transparency, increases consumer control over personal data, promotes security, and allows for continued innovation. Microsoft advocates for both state and comprehensive federal privacy law that sets consistent standards, streamlining compliance and safeguarding privacy rights for all individuals. On the other hand, ITI tends to favor a robust federal privacy law that will enhance consumer trust and limit the harm from an increasing patchwork of state-level privacy regimes that are difficult for consumers and businesses to navigate and undermine the social and economic benefits of data innovation. Microsoft and ITI have a mission built on promoting innovation and responsible data practices. By engaging in constructive discussions, we continue to work collaboratively on policy approaches that effectivley address privacy concerns while fostering technological innovation.

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Fundamental Rights: ITI and Microsoft have similar views on various initiatives concerning fundamental rights. Both Microsoft and ITI hold the position that policymakers should support technical training programs, workforce development programs, and greater funding for STEM and computer science education. To remain globally competitive, the United States' domestic workforce must be equipped to respond to all technological growth areas. Therefore, we have joined ITI efforts to lobby Congress and the administration to advance STEM education and training programs by creating opportunities and pathways that are inclusive to all. We also partner with ITI to advance wireless broadband including 5G deployment and the allocation of unlicensed spectrum supporting technologies like Wi-Fi, an important link in cloud services accessing the internet. We also partner to advance policies that support wireline/fixed broadband deploy and adoption. Both Microsoft and ITI have sought to advance accessibility policy solutions that meet the needs of consumers while also allowing companies to bring new innovative solutions to market.

Microsoft and the Business Roundtable (BRT)

The policy goals of Microsoft and the Business Roundtable are fairly aligned across the key areas reviewed earlier in this report. Our active participation in the U.S. Business Roundtable reflects our shared commitment to promoting accountability, fostering innovation and competitiveness, harmonizing regulations, and achieving global interoperability. To the extent differences exist in the company and trade association's respective positions, we remain committed to engaging in constructive dialogue to understand and address any areas of misalignment.

Sustainability: Like Microsoft, BRT recognizes the real and growing threat of climate change and the push by their CEO Members to embrace environmentally sustainable practices across their businesses. However, there is some misalignment with our policy priorities. For example, Microsoft transparently reports across Scopes 1, 2, and 3 emissions and has been supportive of the SEC and FAR Council proposed rules requiring certain companies and government contractors to report emissions. Federal regulations provide a consistent framework that ensures all companies are held to the same standards, fostering a level playing field and enabling effective emissions reduction strategies. BRT filed comments in opposition to the proposed SEC rule but did not file any comments and stayed neutral on the FAR Council rule at the urging of Microsoft. Despite these differences, we remain a partner with BRT to collaboratively address critical issues impacting businesses and society, with a focus on driving shared prosperity and sustainable economic development whenever possible.

Privacy: We share common goals with BRT framework towards policy, aiming to prioritize consumer trust and accountability. Like us, BRT supports and lobbies for national privacy framework to provide clarity for businesses operating across state lines. However, Microsoft advocates for both state and comprehensive federal privacy law that sets consistent standards, streamlining compliance and safeguarding privacy rights for all individuals. In contrast, BRT expresses concerns about the complexities arising from varying state privacy laws and therefore favors a unified national legislative framework. Therefore, while we share common goals with BRT framework, our differing priorities within lobbying on privacy legislation have limited our engagement with them on this policy area.

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Fundamental Rights: Both Microsoft and BRT are well aligned on our beliefs for policymakers to take urgent action to bridge the digital divide so that all Americans, both rural and urban, can stay connected to their communities, schools, workplaces, and critical services. Like BRT, Microsoft is committed to helping address racial injustice and inequity in the United States for Black and African Americans communities. Microsoft made a five-year commitment to address racial justice and inequity, focused on using data, technology, and partnership to improve the lives of Black people in the US; increasing investment to improve representation and inclusion within Microsoft, and better utilizing our balance sheet and relationship with suppliers to foster larger societal change.

Microsoft and the Software Alliance (BSA)

The policy goals of Microsoft and the Software Alliance are generally aligned across the key areas reviewed earlier in this report. Our participation in BSA reflects our shared commitment to fostering a favorable business environment for software innovation and growth. However, we remain committed to engaging in constructive dialogue to understand and address any areas of misalignment that may arise between the company and trade association's respective positions.

Sustainability: Microsoft and BSA share a commitment to promoting sustainability in the technology industry. Together, we work to drive positive environmental impact through various initiatives. We collaborate on developing and advocating for sustainable practices, including energy efficiency, responsible supply chain management, and reducing electronic waste. By leveraging our collective expertise and resources, we aim to create a more sustainable future, where technological innovation is aligned with environmental stewardship. While Microsoft and BSA share many common goals and collaborate on various aspects of promoting sustainability, there may be some areas where differences exist. These differences can arise due to variations in perspectives, priorities, or approaches to specific issues. However, despite any divergences, we maintain a strong commitment to engaging in constructive dialogue and finding common ground to work towards shared objectives with BSA.

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Privacy: At Microsoft, we actively engage with BSA on various fronts, highlighting our shared goals and addressing key areas of concern, particularly in the realms of privacy and AI. Being a member of BSA allows us to collaborate closely with like-minded enterprise software and cloud services companies who share our commitment to advancing strong state and federal privacy legislation. Like Microsoft, BSA has been laser-focused on ensuring that privacy bills incorporate an important and longstanding concept from global data protection laws, like the EU's General Data Protection Regulation (GDPR): the controller-processor distinction. In short, that concept ensures that privacy laws clearly impose complementary obligations on companies based upon the role they play in the online ecosystem, and that is important to ensure that consumer rights and protections will be effective and will follow their data as it flows throughout the ecosystem. While we may have differing perspectives on certain aspects, such as specific policy approaches, we are firmly committed to collaborating with BSA to find common solutions that strike the right balance between privacy, innovation, and consumer needs. By leveraging our collective expertise and insights, we can foster an environment that promotes responsible data practices while enabling technological advancements.

Fundamental Rights: Microsoft and BSA collaborate to promote fundamental rights in the digital landscape, with a specific focus on accessibility and digital inclusion. Together, we work to advance inclusive design, develop innovative solutions, and advocate for policies that ensure technology is accessible to individuals with disabilities. Additionally, we strive to bridge the digital divide by expanding access to technology and digital skills, particularly for underserved communities. Through these joint efforts, we aim to create a more inclusive and equitable digital society, where everyone has equal opportunities to access and benefit from technology. ### Microsoft's policies, practices, activities, and reporting adhere to a set of transparent principles and standards of conduct. To delve deeper into these principles and to learn more about our public policy engagement, please visit the Microsoft CSR webpage.

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Engagement/Advocacy Report