Incident Reporting and Investigation

This Incident Reporting and Investigation Program outlines the minimum global requirements for reporting work-related incidents, conducting comprehensive investigations, and ensuring adherence to applicable regulatory standards at all locations where Microsoft employees work. For the purposes of this program, work-related incidents include injuries, illnesses, property damage, and near misses.

Accurate and prompt reporting of workplace injuries and illnesses is fundamental to a robust safety management system. Identifying and addressing the root causes of unsafe behaviors, hazardous conditions, and deficiencies in safety programs are crucial in preventing future incidents. Both employees and management play a critical role in recognizing the benefits of incident reporting and investigation as proactive measures to enhance workplace safety.

This document applies to all Microsoft full-time employees (FTEs), interns, and external staff directly supervised by Microsoft FTEs (as required by local regulations), who work at a Microsoft worksite.

External parties not under the direct supervision of Microsoft FTEs are responsible for managing their own regulatory obligations, including notification and recordkeeping requirements. Microsoft will investigate all reported injuries at Microsoft facilities and implement corrective actions as needed to prevent recurrence and ensure the safety and wellbeing of employees. Where appropriate, external workers' employers may participate in these investigations.

Any variation to this global program or creation of a location-specific procedure/plan must be approved through the change management procedure in the Occupational Health and Safety (OHS) Governance Framework.

The following sections outline the incident reporting, investigation, and corrective action processes. Any requests for modifications or additions to this process must be approved by the Global OHS team.

In the event of SafetyHub or Viva Connection issues, a member of the OHS can assist recording the incident as an event via aka.ms/safetyhubreport.

3.1 Microsoft Employees

Note: if you require immediate medical assistance, contact your local emergency services.

Microsoft employees (FTEs) must report injuries, illnesses, hazards, property damage, vehicle accidents, and near misses in the workplace in a timely manner. Reporting shall be made in SafetyHub, via Viva Connections application, by selecting "SafetyHub: Report an injury or safety observation." This function is also accessible via aka.ms/SafetyHubReport. In the event one could not access Viva Connections application, please report your injury to Global OHS.

Once the emergency responder or the employee has ensured personal safety and controlled the injury, the next steps of reporting the incident must be completed:

1. Gather Information: collect relevant details about the incident, not limited to date, time, location, and nature of the event.
2. Report the incident/event in SafetyHub Report (aka.ms/SafetyHubReport). In the event one could not access Viva Connections application, please report your injury to Global OHS.
3. Provide the necessary details and documents to complete the investigation report.
4. Review and follow-up: the employee can request that the OHS Global team provide a follow-up on the incident.

3.2 External Staff

External staff must report all injuries, illnesses, incidents, hazards, and near misses in the workplace to their employer. If the injury, illness, hazard, or near miss occurs within a Microsoft facility, external staff with a v-dash account are required to report via SafetyHub Report (aka.ms/SafetyHubReport).

If the external staff does not have a v-dash @microsoft.com account, the FTE supervisors of external staff can submit via SafetyHub Report at aka.ms/SafetyHubReport on behalf of the external staff. If the supplier company does not have access to an @microsoft.com address, they can report by sending an email to Global OHS.

Suppliers are responsible for managing all related workers' compensation actions for their employers.

3.3 Types of Incidents That Must be Reported

The following nonexhaustive list represents the categories of incidents that must be reported.

• Any Microsoft employee and external staff injury or illness that is work-related (see the Key Terms and Definitions section below).
• Any hazard in the workplace that may cause harm to any employee, external staff, or visitor.
• Any near-miss event or activity that may cause harm to an employee, external staff, or visitor.
• Any vehicle accident, fire, or property damage to any of Microsoft's facilities or equipment.

3.4 Medical Emergencies and Treatment

When an injured Microsoft employee, intern, external staff, or visitor needs immediate medical care in the event of an emergency, call local emergency responders, providing, but not limited to, the following information:

• Company name
• Building number and address
• Exact location within the building
• Your name and phone number
• The nature of the emergency

If a medical situation arises during a Microsoft-approved international business trip, the Microsoft Worldwide Emergency Assistance Program offers 24 hours a day, 7 days a week, assistance. The program offers travel, medical emergency assistance, and accident insurance assistance via dedicated phone lines: 1-888-946-6738 (US/Canada) and +1 253-946-6738 (International).

Once the emergency response is completed and the affected employee(s) have received the needed care, the incident should be reported to SafetyHub, via Viva Connections application, by selecting "SafetyHub: Report an injury or safety observation." This function is also accessible via aka.ms/SafetyHubReport. In the event one could not access Viva Connections application, please report your injury to Global OHS.

In case of an emergency always follow directions provided by the emergency response team. Building evacuation maps are posted throughout the building (i.e. at elevator and stairwell). Once you evacuate the building you will be directed to the designated assembly point or an alternate safe location. Assembly point maps are available from the Lobby Host in each building. First aid, AED kits, and fire extinguisher locations are marked on building evacuation maps. 

3.5 Escalation Procedure for Emergencies

If the incident at a Microsoft workplace involves a fatality or serious incident, Microsoft Global OHS must be notified immediately by reporting to SafetyHub, via Viva Connections application, by selecting "SafetyHub: Report an injury or safety observation." This function is also accessible via aka.ms/SafetyHubReport. In the event one could not access Viva Connections application, please report your injury to Global OHS.

Country-specific OHS program manager or designee will report work-related fatalities or serious injuries to country-specific regulators, as required by applicable regulations.

3.6 Crisis Management Team (CMT)

If the incident involves a fatality or significant property damage, OHS will notify Microsoft Global Security (MGS). At that time, MGS will determine if the local CMT needs to be activated.

Upon notification, the local OHS support will review the Enablon event notification and verify the identification type, recordability, confidentiality, and severity level. OHS shall also assign actions to appropriate individuals for the business site. Severity levels will be determined using the following criteria.

High learning value events (HLVEs) will be shared with relevant stakeholders, in the form of Safety Minutes, to help prevent occurrence elsewhere.

4.1 Investigation Process

An incident investigation process has been developed to accomplish the following:

• Prevent future incidents (leading to accidents)
• Identify and eliminate hazards
• Expose deficiencies in process and/or equipment
• Reduce injury and worker compensation costs
• Maintain worker morale
• Meet relevant local regulatory requirements that investigation might be required for serious accidents.

At a minimum, the following types of incidents require an investigation.

• An employee fatality occurs due to work performed or workplace conditions.
• An employee becomes ill or sustains an injury because of work.
• A chemical is released inappropriately (i.e., into the air, onto the ground, etc.).
• Significant property damage (greater than USD $10,000 or equivalent local currency).
• Near miss with potential for a severe injury, environmental impact, or property damage.
• Any other incident where local legislation requires an investigation.

The investigation process follows these steps:

1. The affected employee reports an incident using the SafetyHub application on Viva Connections. If SafetyHub is not available to the employee, they can also report to their supervisor emailing Global OHS
2. Local OHS Manager will perform the following steps:
   1. Determine whether the case is work related based on local legal requirements.
   2. Determine severity of case and determine immediate actions.
   3. Perform any required reporting to the local government authorities.
   4. Interview witnesses and collect evidence.
   5. Determine the root causes of the incident.
   6. Work with stakeholders to implement corrective actions to address the root causes of the incident.
   7. Communicate learnings to local teams as needed and to the global OHS team as appropriate.

4.2 Investigation Documentation

Investigations must be documented in Enablon, the global health and safety software. Use the following guidance when generating an investigation report.

• The focus of the investigation is to prevent a similar incident from happening again, not finding fault or placing blame.
• Describe the injuries and summarize immediate treatment that occurred but do not include information about any previous or existing medical conditions or ongoing treatment. Medical reports or doctors' notes should not be included in the investigation documentation.
• Remain objective. Avoid opinions, speculation, and hearsay. Include enough detail so that the report is understandable to someone outside the investigation team.
• Include any photographs, training records, or other information to support the findings of the investigation. Consider confidentiality and privacy requirements when deciding whether to include photographs. Obtain permission from the appropriate business group and/or individual as necessary before sharing photographs or images that could be tied to an individual(s). With photographs, avoid including identifying images that include face or individuals, unless required to document the incident.

Once the investigation of the incident is complete, the incident event should be updated in Enablon to include the findings, corrective actions, and reporting status.

The local OHS manager will communicate the results of the investigation with any local groups that face similar hazards or risks using communication tools such as safety minutes. If the learning may have a global application, contact the Global OHS team for help coordinating communications.

6.1 Recordable Cases

Work-related injuries and illnesses that result in any of the following could be considered recordable:

• Death.
• Loss of consciousness.
• Days away from work because of work related injury or illness.
• Restricted work activity or job transfer.
• Medical treatment beyond first aid.

You must consider as "recordable" for the purposes of this program any work-related injury or illness diagnosed by a physician or other licensed health care professional.

Microsoft leverages one definition for recordability for internal reporting, but the definition of recordability may vary by local regulations. When reporting externally, the local definition will be followed.

6.2 Record Retention

All incidents must be recorded via Viva Connections (aka.ms/SafetyHubReport). These reports will be logged directly into Enablon. All documents related to incident investigations should also be stored in Enablon. Records will be retained according to Microsoft's Corporate Retention policy as follows:

All new employees including interns are required to complete the Microsoft new employee health and safety training within 90 days of their start date, as part of their onboarding process, on top of role-specific requirements tailored. Awareness training is available to all employees but may be required for employees who perform work with higher risks. Incident investigation training will be provided for employees responsible for conducting incident investigations.

The following terms are used in this document. The definitions below are used in the scope of this document, but local regulatory definitions supersede if there is a conflict.

Emergency: A serious situation or occurrence that happens suddenly or unexpectedly, jeopardizing human life or property, and demands immediate action (e.g., severe bleeding, heart attack symptoms, stroke, chest pain, difficulty breathing, compound fractures, etc.).

Emergency response: The response made by firefighters, emergency medical technicians, security, health care personnel, and/or other emergency services upon notification of a fire, accident, earthquake, explosion, environmental spill/event, or other event in which human life and/or property may be in jeopardy.

Enablon: A web application to record events and track actions that include incidents, observations, and inspections.

Environmental incident: An unplanned event or a release of a regulated substance that may result in an impact to human health, the community, the environment, or wildlife and sensitive and protected areas or be of interest to the media or a permit or regulatory exceedance that may result in an issuance of an NOV (notice of violation by a regulatory agency).

Corrective action: An action or activity that eliminates a hazard determined to be a root cause of an incident. Each root cause uncovered in an incident investigation should be accompanied by at least one corrective action that will prevent reoccurrence of the incident.

First aid: A one-time, short-term treatment of a work-related injury or illness that requires little or no technology or training to administer and can be administered by the injured/ill worker or another individual without intervention by a medical professional. Examples include:

1. Cleaning, flushing, or soaking wounds on the surface.
2. Wound coverings (does not include "closure," i.e., an open wound that could otherwise be treated with sutures), such as using bandages, gauze pads, and strip adhesives.
3. Nonprescription medication.
4. Tetanus immunization in response to exposure (other immunization are treatment).
5. Hot or cold therapy.
6. Temporary immobilization devices while transporting, i.e., splint, neck brace, back board.
7. Eye patch (by itself).
8. Drilling fingernail to relieve pressure.
9. Draining fluid from a blister.
10. Removing splinters or foreign material with irrigation, tweezers, cotton swabs, or simple means.
11. Finger guard to protect tip of finger.
12. Simple massage.
13. Drinking fluids to relieve heat stress.

High learning value event: When checked in Enablon, this event will be visible as read-only to every Enablon user, regardless of location. Personal information associated with an event and impact will only be visible to Event Creator.

Incident: An unplanned and unwanted event that disrupts the work process and may result in injury, harm, or damage to persons or property.

Lost time injury: Work-related injuries or illnesses that result in an employee's absence from work.

Major incident: Work-related injuries or illnesses that require medical treatment beyond first aid. Environmental spills or releases that flow into waterways or onto soil that require reporting the incident to state or federal authorities.

Medical treatment beyond first aid: (see definition for First Aid):

Is the management and care of a patient for injuries or illnesses other than those listed in First Aid.

Examples:

1. Prescription medication: if prescribed, even if not taken or picked up at the pharmacy. This includes "preventive" antibiotics.
2. Procedures: wound closure (sutures or adhesive strips), CPR, AED, supplemental oxygen, or IV fluids to treat symptoms. Emergency procedures do not have to be administered by a licensed health care professional.
3. Specific conditions/diagnoses even if "no medical treatment was received."
   1. Loss of consciousness.
   2. Injuries from needles or other contaminated sharp objects.
   3. Occupational exposure to infectious diseases, i.e., malaria, tuberculosis, and hepatitis C as confirmed by clinical testing or a licensed health care professional. Note: does not include incidents if incurred by a national worker and the disease is endemic to the work environment (i.e., malaria in an endemic area).

Medical treatment does not include:

Visits to a physician or other licensed health care professional solely for observation or counseling.

The conduct of diagnostic procedures, such as X-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes (i.e., eye drops to dilate pupils).

Near miss: A near miss is an unplanned event that did not result in injury, illness, or damage but may have done so. An incident may disrupt the work process but does not result in injury or damage. It should be looked at as a "wake-up" call. It can be thought of as the first of a series of events that could lead to a situation in which harm or damage occurs.

Occupational illness: An occupational illness (or disease) is any abnormal condition or any illness directly attributable to acute or chronic workplace exposure including skin diseases and disorders, respiratory conditions, poisoning, hearing loss, heat or cold stresses, and others. An illness may include significant aggravation to a preexisting illness.

Occupational injury: Any wound or damage to the body resulting from an event in the work environment. This could include significant aggravation to a preexisting injury.

Recordable injury/illness: (USA only) An injury or illness that meets the general recording criteria. An injury or illness is recordable if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, or is a significant injury or illness diagnosed by a physician or other licensed health care professional.

Restricted time injury: Work-related injury or illness that prevents an employee from performing routine functions of their job. A physician or other licensed health care provider may be involved in recommending restrictions based on the nature of the injury or illness.

Root cause: A system failure or hazard that was the main contributor to an incident. If this had not existed, the incident would not have happened. Typically, an incident has more than one root cause.

Witness: A person who has information relevant for an incident investigation. This person could be the affected employee, an eyewitness, a subject-matter expert, or someone who can supply records or other information relevant to an investigation.

Workers' compensation: A form of insurance required by employers that provides money as compensation for workers injured at work or who contract an occupational disease. Microsoft FTEs can request assistance with workers' compensation claims from AskHR. External staff (non-FTEs) request assistance through the appropriate workers' compensation program associated with their employer.

Work-related: An injury or illness is considered work-related if an event or exposure in the work environment caused or contributed to the condition or significantly aggravated a preexisting condition. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the workplace.

The work environment includes the establishment and other locations where one or more employees are working or are present as a condition of their employment.

Generally, incidents that occur in the workplace are work-related. In some jurisdictions, incidents that occur during commute, off-site company-sponsored events, or business-approved travels may be considered work-related.

Microsoft Internal

Microsoft internal safety programs can be accessed here: SafetyHub programs and guidance.

International Labour Organization (ILO): The ILO is a specialized agency of the United Nations that sets international labor standards and promotes decent work for all. It has developed numerous conventions and recommendations related to occupational health and safety (OHS), covering topics such as the prevention of occupational accidents and diseases, protection of workers' rights, and promotion of healthy workplaces. The ILO's Convention No. 155 concerning occupational health and safety and its Recommendation No. 164 provide guidelines on incident reporting and investigation. These instruments emphasize the importance of establishing procedures for reporting and investigating occupational accidents and diseases to prevent their recurrence.

World Health Organization (WHO): The WHO addresses occupational health and safety as an integral part of its focus on promoting public health globally. Although the WHO does not have mandatory regulatory frameworks like some regional or national organizations, it provides guidelines, recommendations, and technical support to member countries to strengthen their occupational health and safety systems.

United Nations Sustainable Development Goals (SDGs): Goal 8 of the SDGs focuses on promoting sustained, inclusive, and sustainable economic growth, full and productive employment, and decent work for all. This includes targets related to reducing workplace injuries and fatalities through effective incident reporting and investigation practices, contributing to sustainable economic growth, and decent work opportunities.

Occupational Safety and Health Administration (OSHA): In the United States, the common regulations related to incident reporting and investigation primarily fall under the oversight of OSHA. OSHA covers most private-sector employers and workers in all 50 US states, the District of Columbia, and the other (US) jurisdictions—either directly through OSHA or through an OSHA-approved state plan. OSHA mandates incident reporting requirements under various regulations, such as the Recordkeeping Rule (29 CFR Part 1904). This rule requires employers to record and report work-related fatalities, injuries, and illnesses and to conduct thorough investigations to determine root causes and implement corrective actions. Regulations (Standards - 29 CFR) | OSHA.gov | Occupational Safety and Health Administration

• OSHA fact sheet. The Importance of Root Cause Analysis During Incident Investigation (PDF) (2016). This fact sheet provides guidance for identifying root causes of incidents and/or near misses to prevent their recurrence.
• OSHA. Incident Investigation - Overview | Occupational Safety and Health Administration. This guidance document provides employers with a systems approach to identifying and controlling the underlying or root causes of all incidents to prevent their recurrence.
• National Safety Council. Investigate to Find Facts, Not Faults - National Safety Council 5-Minute Safety Talk
• Washington State Department of Labor & Industries. Accident Investigation Basics (2009). This PowerPoint-based online training module provides an overview about conducting root-cause workplace incident investigations.

European Union (EU) directives: The EU has established directives on health and safety at work that set minimum requirements for member states. Framework Directive 89/391/EEC outlines general principles for managing health and safety at work, including incident reporting and investigation. Specific directives, such as 89/656/EEC that reflect the use of personal protective equipment, also require employers to investigate accidents and incidents to prevent recurrence. EU Directive 92/58/EEC deals with the minimum requirements for the provision of safety and/or health signs at work. It ensures that workers are informed about potential hazards and the necessary actions to take in case of an incident.

North American Agreement on Labor Cooperation (NAALC): Part of the North American Free Trade Agreement (NAFTA), NAALC promotes cooperation among the United States, Canada, and Mexico on labor issues, including occupational health and safety. It includes commitments to enforce labor laws and ensure effective labor protections. It indirectly supports incident reporting and investigation through its commitment to ensuring safe working conditions across North America.

International Standards Organization (ISO): ISO 45001 provides a framework for occupational health and safety management systems, including requirements for incident reporting and investigation (Clause 10). It emphasizes the need for organizations to establish, implement, maintain, and continually improve processes for reporting incidents, investigating their causes, and taking corrective actions.

Federally Sponsored Safety Regulations

Occupational Safety and Health Administration (OSHA) State Plans: osha.gov/stateplans