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Last week, Microsoft made public a report on the effectiveness of workplace sexual harassment and gender discrimination policies. This report was initiated as a result of “the Shareholder Resolution that was approved by shareholders at the Company’s annual meeting on November 30, 2021” and was conducted by the law firm ArentFox Schiff. This report is really two reports – the first is ArentFox Schiff’s report on their findings and the second is Microsoft’s report on their action plan in response to the findings.

The investigation found that the company should “consider implementing certain enhancements to their existing policies, procedures, and practices” as follows:

  1. Revise the Anti-Harassment and Anti-Discrimination Policies
  2. Establish a Formal Procedure to Request Reconsideration of an Investigation’s Findings
  3. Require the Disclosure of Certain Consensual Relationships
  4. Develop an Effective Tool to Remind Employees They Need to Take Required Trainings
  5. Advise Employees of their Rights to Seek External Relief
  6. Ask Complainants to Complete Surveys About Their Investigation Experience
  7. Establish Credible Transparency Around Remediation
  8. Take Steps to Minimize Perception that Senior Leaders Are Not Held Accountable
  9. Coordinate Data Among Human Resources (“HR”), Workplace Investigations Team (“WIT”), Global Employee Relations (“GER”), and Corporate and External Legal Affairs (“CELA”)
  10. Make Improvements to the WIT Investigation Process
  11. Continue Efforts to Increase the Percentage of Women in Leadership Positions

The company’s implementation plan reports that “Microsoft management has created a comprehensive implementation plan to act on the recommendations and hereby submits this summary of its plan for Board review. Management’s plan encompasses all eleven recommendations from the audit report.”

This may set quite a precedent and is likely to embolden other shareholders in pushing for similar investigations at other companies. It would be prudent to review the investigation report and determine if similar gaps/opportunities for improvement exist in your company as a preemptive measure.

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The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile