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)