Microsoft has released the results of an independent transparency report on the company’s handling of harassment and discrimination policies.

Following a successful shareholder resolution, Microsoft’s board ordered an independent review of its harassment and discrimination policies, including how it handled allegations against Bill Gates. The firm that handled the review, ArentFox Schiff LLP, has completed its work, and Microsoft has released the results.

The report shows that Microsoft does a good job overall in terms of its policies and procedures:

Microsoft has robust policies, trainings, and complaint and investigation procedures addressing the issues of gender discrimination and sexual harassment, and has made meaningful efforts to make improvements in these areas during the period covered by this Project. Our review revealed that the Company strives to follow best practices in these areas, and espouses a dedication to continual improvement.

Nonetheless, the firm did find areas where the company could improve, especially in handling cases sooner. The firm references the company’s so-called “golden boys,” a group of executives that seemingly were given a free pass on inappropriate behavior because they are viewed as some of the company’s most valuable executives.

First, that there is and has been a perception among some employees that the Company tolerates and to some degree protects high performing senior executives who may be engaging in inappropriate conduct. Second, due to the volume of complaints against these Corporate Vice Presidents, there was at least a perception and a degree of evidence that they were engaging in inappropriate conduct toward female employees that could have been addressed earlier than it was. Third, although multiple people from HR, GER, ERIT, and WIT had knowledge of various allegations against these executives, it did not seem that any one of them had all of the knowledge of all of the allegations, which may have been useful in addressing the situation earlier. We have made some recommendations to address these observations below.

Interestingly, the report did not shed any new light on the allegations against Gates, nor did it add anything to Microsoft’s own internal investigation. This would seem to support the findings and results of Microsoft’s original investigation.

For its part, Microsoft has promised to implement the suggestions in the report in an effort to shore up the areas where it has fallen short:

ArentFox has completed its work and has provided the Board with a report detailing its findings and recommendations. In addition, the Microsoft management team has prepared an implementation plan that addresses all the recommendations in the ArentFox report. In many cases, the recommendations build on and extend work already in progress. The Board has thoroughly reviewed the ArentFox report, and it has approved the specific actions in the implementation plan.

“Cultivating a culture where everyone is empowered to do meaningful work and can thrive is our greatest responsibility at Microsoft,” said Satya Nadella, Chairman and CEO, Microsoft. “The Board of Directors has taken this investigation seriously and the resulting comprehensive report outlines important areas where we can continue to improve, as well as progress we’ve made. The Board of Directors and our senior leaders are fully committed to this implementation plan as we continually work to close the gap between our espoused culture and the lived experience of our employees.”