Microsoft's State-Owned Entity Criteria

An entity should be treated as state owned if 1) it is controlled by the government or 2)

it performs a function the controlling government treats as its own. An employee of a
state-owned entity should be treated as a government official for the purposes of
compliance with Microsoft Anti-Corruption Policy.
An entity is government controlled if any one or more of the following factors apply:

1. The government owns 30% or more of the entity;

2. The government has voting control or the ability to appoint officers or directors;
3. The government has formally identified the entity as a government agency or
SOE;
4. The entity is financed through government appropriations, tax revenue, licenses,
fees, or royalties;
5. The entity’s profits are paid or go directly to the government;
6. The government subsidizes the entity’s costs of providing services; or
7. The entity is funded by the government in the event it fails to “break even.”

An entity performs a function that the controlling government treats as its own if
any one or more of the following factors apply:

1. The government designates the entity as performing a governmental function or

otherwise clearly indicates that the entity is performing a function expressed in the
government’s policies;
2. The public generally perceives the entity to be performing a governmental
function;
3. The entity has a monopoly over the function it carries out, or exclusive power to
administer the function it carries out;
4. Employees of the entity are considered to be public officials or civil servants; or
5. The entity provides services, which the government treats as its own, to the public
at large. For example:
 Public medical/healthcare or life-science services
 National defense / aerospace
 Public educational services
 Public transportation
 National banking or financial services
 National utility or infrastructure services (e.g., telecommunications, gas,
electric, water, sewage)
 State media (e.g., broadcast, print)
 Energy exploration, extraction, and development (including oil and gas)