After intense litigation in the early 2000s, Microsoft Corporation entered agreements to settle antitrust suits with the Justice Department, the Federal Trade Commission, and the Securities and Exchange Commission. This led to the creation of a "general code of conduct" that tells all employees their obligations under the law and "provides principled, ethical pathways," according to Microsoft Compliance Director Odell Guyton.

This image shows Mary Snapp (left), Microsoft deputy general counsel, and Brad Smith, Microsoft general counsel and chief compliance officer. They were among a handful of lawyers at Microsoft that spent the majority of their time on compliance efforts.

Mary Snapp was the first female attorney hired at Microsoft, and as of 2025 is the Corporate Vice President of Microsoft Philanthropy. Brad Smith would become President of Microsoft in 2015 and Vice Chairman in 2021.

Caption information source: "Compliance enters Microsoft corporate code," by Dan Richman, Seattle Post-Intelligencer, August 30, 2002, p. 1, 11-12.