We comply with the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act, the French Sapin II, the Canadian Corruption of Foreign Public Officials Act, the Brazil Clean Companies Act, the Swiss Criminal Code, and all other applicable anti-corruption laws and regulations wherever we do business.

We will not engage in bribery or corruption, look the other way, or ignore red flags of corruption that we may encounter in our business. We prohibit our team members and those acting on our behalf from accepting, offering, promising, or making improper payments or bribes, or engaging in influence peddling, to improperly impact a business decision or gain a business advantage.

For example, we will not use gifts, meals, entertainment, travel, employment, paid or unpaid internships, sponsorships, charitable donations, or other benefits to or from a third party to improperly influence a government or private party decision or to gain a business advantage. We will not request or accept any bribe, kickback, or other improper payment or benefit to award a FedEx contract or business to a third party.

FedEx prohibits our team members and those acting on our behalf from engaging in bribery and other corrupt schemes like kickbacks, improper payments, or trading in influence. If you are asked to make an improper payment or bribe, or are offered a bribe or kickback, immediately contact your manager and the legal department or the FedEx Alert Line to report the matter. These acts are illegal in most countries and can expose you and FedEx to criminal prosecution and other penalties.

Unfortunately, corrupt individuals may use threats to try to force or extort an improper payment. If someone threatens your health or safety, do what is necessary to protect yourself. Then report the incident, including whether you were forced to make a payment, to your manager and the legal department or FedEx Alert Line as soon as possible.

Finally, we maintain internal financial controls to prevent and detect bribery and corruption. We keep accurate books and records. We properly record all payments and do not try to conceal any improper payments within our books and records. Accuracy and details matter.

Our business dealings with vendors, consultants, service providers, and other third parties are based on principles of honesty, fairness, and respect. We select and keep suppliers and other third-party business acquaintances on merit. We hold these third parties to the same high standards we have for our own behavior and ethical decision-making, and we expect them to be trustworthy and accountable.

Red flags of money laundering include:

• Requests for large cash payments or other unusual payment terms.
• Structuring or breaking down payments into smaller amounts or dividing transactions into amounts that avoid government reporting requirements.
• Fund transfers to or from countries or territories unrelated to the transaction.
• Fund transfers to or from unrelated parties.
• Reluctance by a third party, customer, or supplier to supply complete or truthful contact information.
• Other activities outside the normal course of business.

If you become suspicious of potential money laundering activities, speak with your manager, the legal department, or the FedEx Alert Line at once.

Gifts, meals, travel, and entertainment should be moderate, appropriate to the region or local culture, and intended only to promote FedEx business relationships. When giving or receiving gifts, meals, travel, or entertainment, we must understand and follow our policy requirements.

Team members may accept gifts, meals, or entertainment from a third party in these instances:

• Are infrequent, not asked for, and not lavish or excessive.
• Are not intended as a bribe, payoff, or kickback.
• Do not create the appearance of preferential treatment.
• Are reasonable and business-appropriate.
• Are in line with any specific policy limits.

While we are employed by FedEx, our primary business loyalty must be to FedEx. There may be a conflict of interest when something or someone we are personally involved with outside of work at FedEx may interfere with our responsibilities to FedEx. When we have a conflict of interest, it can affect our ability to act sincerely and in the best interests of FedEx when making business decisions.

To avoid conflicts of interest, we must avoid activities, investments, or close personal relationships that create, or appear to create, a conflict between our personal interests and the interests of FedEx. In addition, FedEx specifically prohibits team members or their close personal relationships from accepting money, gifts, or personal benefits in return for awarding FedEx business.

Unless preapproved by the Executive Vice President and Chief Financial Officer of FedEx Corporation, you may not hire any person who has been employed during the preceding three years by the independent auditor of FedEx (currently, Ernst & Young LLP)

Common situations that could create a conflict of interest for a team member include:

• Having a second job outside FedEx that negatively affects your work at FedEx.
• Working for FedEx competitors, customers, or suppliers.
• Hiring or supervising a close friend, family member, or romantic partner.
• Using FedEx property, resources, opportunities, or ideas for personal gain.
• Holding significant financial interests in or exercising control over a customer, supplier, or competitor.
• Awarding a FedEx contract to a relative or friend.
• Receiving a personal benefit from a company doing business with FedEx.

As a global company, we must be aware of export controls and sanctions that govern business dealings with certain countries, entities, and individuals. These rules exist to protect national security interests, enforce international laws, defend human rights, maintain peace and security, and prevent armed conflicts. Penalties for breaking sanctions can include fines, asset seizures, and prison sentences.

FedEx maintains policies and procedures to help ensure that we:

• Do not operate or provide services to individuals, entities, countries, or territories in violation of U.S. and other relevant trade sanctions.
• Screen transactions, including shipments, vendors, and other third parties, to identify people or entities on restricted or sanctioned party lists.
• Remain alert for and report red flags indicating diversion to a prohibited country or party.
• Do not deliver shipments of items that are prohibited for import or export.
• Do not transfer controlled technology, equipment, or software without required import or export authorization.

As a U.S.-based company, FedEx does not and may not take part in boycotts that are not supported by the U.S. government, such as agreements to discriminate based on race, religion, gender, national origin, or nationality, or refusal to do business with certain countries not sanctioned by the U.S. Any action of this nature can subject FedEx to substantial penalties and have a serious impact on our operations.

Regardless of where we are located, we must understand and follow all applicable export controls, trade embargoes, and economic sanctions imposed by the U.S. and governments of any country or territory where we operate.

FedEx thrives in competitive markets. We are committed to giving customers the best value for our products and services. Antitrust and competition laws are designed to protect customers by promoting healthy competition, which results in lower prices, more choice, better quality, and greater innovation. Actions that violate antitrust and competition laws, such as agreements with competitors to fix prices, divide customers or markets, or not recruit each other’s employees, are prohibited.

Agreements among competitors can lead to serious and damaging antitrust violations. Such agreements do not need to be written. They can be inferred from actions such as meetings, informal conversation, or the exchange of confidential information. We must be careful when we interact with competitors so we avoid even the appearance of an antitrust violation.

As a trusted global delivery brand, we have an important responsibility to accurately present our products and services in the marketplace. FedEx is committed to fair, accurate, and honest sales and marketing practices. We treat our customers ethically and fairly. We earn their business and trust based on our superior solutions, excellent customer service, and competitive prices.