Fedex Policy: Legal Or Not?

FedEx has a comprehensive code of conduct that covers legal, ethical, and behavioural expectations for its team members. The company is committed to ethical behaviour, integrity, and compliance with the law. Its policies cover a range of issues, including conflicts of interest, anti-corruption, data protection, and human rights. FedEx encourages its team members to speak up and report any concerns or violations. The company has an open-door policy, allowing team members to speak with managers, human resources, or legal representatives at any time. FedEx prohibits retaliation against individuals who report concerns in good faith. While FedEx's policies aim to uphold the law, it is unclear if any specific policies may inadvertently break the law in certain jurisdictions.

FedEx's antitrust and competition law compliance

FedEx has a strong commitment to conducting its business lawfully and ethically, and to being above reproach. The company has a comprehensive antitrust and competition law compliance policy, which applies to every officer, director, manager and employee (collectively referred to as "team members") of FedEx Corporation and its subsidiary companies.

The policy outlines that team members must comply with all applicable antitrust and competition laws, with the understanding that these laws benefit customers by promoting lower prices, more choice and greater innovation. Actions that violate these laws, such as agreements among competitors to fix prices or divide customers, territories or markets, are prohibited and contrary to the way FedEx conducts its business.

To ensure compliance, team members must follow these core principles:

• Refrain from proposing or entering into any formal or informal agreement, arrangement or understanding with competitors regarding prices, discounts, sales promotions, bids, terms and conditions of sale or purchase, customers, territories, markets, wages, employee recruiting, business plans, boycotting, or any other aspect of competition or business.
• Keep all commercially sensitive information confidential and do not share it with competitors, either directly or indirectly through third parties.
• Do not propose or enter into any agreement that sets or controls the price at which a third party may resell a product or service without prior written approval from the Legal Department.
• Obtain written approval from the Legal Department before participating in any trade association and avoid contacts with competitor employees that could create an appearance of an improper agreement or inappropriate information exchange.

The policy also outlines specific scenarios that could lead to conflicts of interest and provides guidance on how to recognise and disclose such situations.

FedEx takes its compliance obligations seriously and has established reporting and anti-retaliation policies to encourage team members to speak up and report any suspected violations. Disciplinary actions, including termination, may be taken against those who do not comply with the antitrust and competition law compliance policy.

FedEx's conflicts of interest policy

FedEx has a long-standing commitment not only to perform lawfully and ethically but to be above reproach. The company's conflicts of interest policy reinforces its commitment to maintaining the highest standard of business conduct and ethics as set forth in the FedEx Code of Conduct. The requirements of this policy are designed to help FedEx team members avoid even the appearance of a conflict of interest and recognize when to get help or report a concern.

Scope

This policy applies to every officer, director, manager, and employee (collectively referred to as "team members") of FedEx Corporation and its subsidiary companies worldwide.

Definitions

• "Close Personal Relationship" refers to individuals who are related by blood, marriage, or law (e.g., spouse, parent, in-law, sibling, child, grandparent, etc.), individuals who live together, and those who are dating or engaging in an intimate relationship or any other similar situation.
• "Conflicts of Interest" include situations where a team member's personal interests or close personal relationships create, potentially create, or appear to create a conflict with their responsibilities at FedEx or compromise the company's interests.
• "Personal Interest" refers to a team member's situation or circumstances outside of FedEx that could create, potentially create, or appear to create a financial or other benefit for themselves or their close personal relationships.
• "Third Party" means any non-FedEx entity, including customers, prospective customers, suppliers, service providers, and any person with whom FedEx does or may do business.

Overview of Team Member Responsibilities

FedEx team members have a duty to:

• Act and conduct business in a manner that promotes the best interests of FedEx.
• Avoid activities, relationships, and situations that create an actual, potential, or apparent conflict of interest between their personal interests and those of FedEx.
• Disclose conflicts of interest to their manager, the company's human resources department, or legal department as soon as they become aware of the situation.

Identification and Disclosure

A conflict of interest exists when a team member's personal interests are, may be, or appear to be incompatible with those of FedEx. While employed at FedEx, an individual's primary business loyalty must lie with the company. As such, they must not engage in activities that create a situation where their loyalties are, may be, or appear to be divided.

Conflicts also occur when a team member making a FedEx business decision is, could be, or appears to be influenced by their own personal benefit or that of a close personal relationship.

Team members must avoid creating situations that result in a conflict of interest with FedEx. When a conflict of interest arises, is discovered, or is believed likely to occur, it must be immediately disclosed in writing to a manager, the human resources department, or the legal department.

Managers who receive notice of a conflict of interest must immediately contact the human resources or legal department for assessment and appropriate action. Each FedEx operating company or international region is responsible for implementing procedures for team members to follow when disclosing, evaluating, and recording conflicts of interest.

To help recognize conflict of interest situations, team members should ask themselves the following questions:

• Can I represent FedEx's interests as my first business priority, or could my personal interests compromise my judgment?
• Am I faced with making a decision that could benefit FedEx but also provides a related personal benefit for me?
• Could others perceive my behavior as a conflict of interest?

Conflicts of interest can occur under various circumstances, and the guidance and situations described in this policy can help team members recognize and properly avoid and disclose them.

Financial Interests

A conflict can arise if a team member or someone with whom they have a close personal relationship is employed by, compensated by, or has a financial interest in a company doing business with, attempting to do business with, or competing against FedEx. When aware of an actual, potential, or apparent conflict in this or a similar situation, team members must disclose the concern to their manager, human resources, or legal department.

Routine FedEx shipping business conducted with someone with whom a team member has a close personal relationship is generally not considered a conflict of interest. However, a conflict could occur with FedEx shipping customers if the team member has significant decision-making authority over FedEx business conducted with that person.

Team members must remain objective when making FedEx business decisions and disclose any conflicts of interest to their manager, human resources, or legal department. They must never use their influence or position to affect the selection or oversee the work of a third party in which they or a close personal relationship are involved.

Corporate Opportunities

If, due to their status as a FedEx team member, an individual learns of a business opportunity that could benefit the company, they may not take that opportunity for their personal benefit or that of their close personal relationships unless they first disclose the opportunity in writing to their manager, human resources, or legal department and obtain legal department approval.

Employing or Supervising Relatives or Other Close Personal Relationships

All team members are responsible for maintaining a culture of trust and respect in the workplace. Managers must never hire, supervise, promote, discipline, or influence the compensation or work assignment of a close personal relationship without written permission from the legal department. Any questions or concerns should be raised with the relevant departments as needed.

Improper Exercise of Influence

Team members must not use their FedEx position to affect a third party's decision to make a charitable or political contribution to a particular entity or person. Refer to the operating company policy on solicitation for more information.

Outside Engagements

Team members should not take additional employment with an outside entity, operate their own business, or hold a public office if the activity will interfere with their job duties or primary business loyalty to FedEx. They must also not use FedEx confidential information, property, or systems for matters not related to the company, even if no other conflict exists.

Team members must also comply with their operating company's policy on outside employment.

Key Points to Remember

• To remain objective, team members must retain their independence in making business decisions.
• Making the best decision for FedEx means acting free from the influence of personal interests.
• Put FedEx's interests first at work, make objective decisions, and consider how a decision would look if made public with full knowledge of the facts.
• Disclose conflicts of interest to the relevant departments.

Reporting and Anti-Retaliation Policy

Team members who know or suspect a violation of this policy should report it to their manager, human resources, legal department, or the FedEx Alert Line.

FedEx prohibits retaliation

FedEx's anti-bribery and anti-corruption policies

As a company doing business globally, FedEx is committed to being ethical and lawful. The company's reputation as a trusted shipping provider depends on the business actions and reputations of its team members.

The FedEx Code of Conduct is a resource for all team members and covers key legal, ethical, and behavioral expectations that every FedEx team member is required to follow. This includes a strict anti-bribery and anti-corruption stance.

The Code of Conduct outlines that team members must refuse to engage in corruption and bribery, maintain ethical third-party relationships, and prevent money laundering. It also emphasizes the importance of avoiding conflicts of interest, abiding by international trade controls, and competing with integrity.

In addition to the Code of Conduct, FedEx has implemented specific policies and guidelines to ensure compliance with antitrust and competition laws. The company thrives in competitive markets and is committed to complying with all applicable laws. FedEx encourages team members to speak up and report any violations of its policies through various channels, including the FedEx Alert Line, which can be done anonymously.

The company's commitment to ethical behavior and integrity is evident in its policies and practices, demonstrating that it takes its responsibility as a global business seriously.

FedEx's data protection and privacy policies

FedEx is committed to protecting its customers' personal data and complying with local and international data privacy laws and standards. The company has a Global Privacy Policy ("Policy") that applies worldwide to all employees and companies of FedEx. This Policy is based on globally accepted, basic principles of data protection and outlines specific guidelines for data handling and employee responsibilities.

Data Protection Principles

According to the Policy, personal data will be collected, recorded, and used in a proper and professional manner, regardless of the format in which it is stored. The company is accountable for demonstrating compliance with the following principles:

• Fair and Lawful: When processing personal data, FedEx must protect the rights of the individual. Data must be collected and processed fairly and lawfully.
• Purpose Specification: Personal data can only be used for the purpose defined at the time of collection and must not be used for any incompatible purposes. It cannot be collected and stored for potential future use unless allowed by local law.
• Collection Limitation: FedEx will only collect the personal data necessary to meet the specified purpose at the time of collection and only to the extent permitted by local law.
• Deletion: Personal data that is no longer needed for the specified purpose will be deleted according to applicable retention schedules unless an exception is granted by the Legal Department.
• Data Quality: Personal data should be accurate and kept up to date if necessary.
• Security Safeguards: Technical, managerial, and physical security measures must be implemented to protect personal data from the risk of loss or unauthorized access, destruction, use, modification, or disclosure.
• Transparency: Individuals must be notified of how their personal data is being used or processed at the time of collection. They must know who is collecting the data, the purpose of the processing, and if third parties will be involved. All such notifications must be approved by the Legal Department.
• Individual Participation: Individuals have the right to access, correct, or delete their personal data, as well as exercise any other rights provided by local law.

Employee Responsibilities

Employees are prohibited from unauthorised processing of personal data and are only permitted to access personal data relevant to their job scope. They are also prohibited from using personal data outside of their employment at FedEx, disclosing it to unauthorised persons, or making it available outside of permitted business use. Supervisors must inform their employees about the obligation to protect personal data at the start of their employment, and this obligation remains even after employment ends.

In the event of suspicious activity, a suspected cyberattack, a suspected security incident, or a possible breach of personal data, employees must immediately notify Information Security.

Special Circumstances

The Policy also outlines special considerations for data transferring or processing by third parties, processing of special categories of personal data, and the use of telecommunications and the internet.

FedEx's anti-retaliation policy

FedEx encourages team members to speak up and report violations of its policies. Team members can report violations to their management, the Human Resources or Legal Department, or the FedEx Alert Line. Reports can be made online or, in most countries, by calling a toll-free number. The FedEx Alert Line is available 24 hours a day, and reports are treated confidentially and, where allowed by law, can be made anonymously.

FedEx prohibits retaliation against anyone who reports a known or suspected violation in good faith. The company also prohibits retaliation against anyone who assists in an investigation. Any team member found to have retaliated against someone who has reported a violation in good faith or assisted in an investigation will be subject to disciplinary action, up to and including termination, to the extent permissible under local law.

Team members are responsible for helping to prevent illegal, unethical, unsafe, or other improper activity. By speaking up, team members preserve the FedEx culture and protect others.

Frequently asked questions