Policy Statement

Introduction

Policy Overview

FedEx thrives in competitive markets and we are committed to complying with all antitrust and competition laws applicable to our global business.  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 simply not the way FedEx does business.

Scope

This Policy applies to every officer, director, manager and employee (collectively “Team Member”) of FedEx Corporation and its subsidiary companies (“FedEx”).  Every Team Member must comply with all applicable antitrust and competition laws.  Penalties for violating these laws can be severe and include large financial penalties, loss of business opportunities, and even individual fines and prison sentences in some countries.  In addition to penalties or fines, violations also can result in the loss of customer trust that can have significant and long-lasting impacts on our business.

Overview of Team Member Responsibilities

While antitrust and competition laws can be complex and their requirements can vary by country or territory, to help ensure compliance every Team Member must follow these core principles:

• Do not propose or enter into any formal or informal agreement, arrangement or understanding with any actual or potential FedEx competitor concerning prices, discounts, surcharges, sales promotions, bids, terms and conditions of sale or purchase, costs, profit margins, customers, territories or markets, market shares, wages, employee recruiting or hiring, business plans or strategies, boycotting or otherwise refusing to do business with any third party, or any other aspect of competition or our business.
• Keep confidential all FedEx commercially sensitive information and do not share such information with an actual or potential competitor either directly or indirectly through a third party, such as a common customer or supplier.  This includes information related to the topics listed immediately above.  If you receive such information from an actual or potential competitor (directly or indirectly), do not share or forward this information and contact your company’s Legal Department immediately.
• Do not propose or enter into any formal or informal agreement, arrangement or understanding that sets or controls the price at which a third party may resell a product or service without specific prior written approval from your company’s Legal Department.
• Obtain written approval from your company’s Legal Department before participating in any trade association (whether through formal membership, meeting attendance or otherwise) and avoid contacts with competitor employees at trade association or other events that could create an appearance of an improper agreement or inappropriate information exchange among competitors.  Object immediately to any suggestion of an improper agreement or inappropriate information exchange among competitors and contact your company’s Legal Department immediately.

Antitrust and Competition Law Guidelines

In addition to the core principles contained in this Policy, understand and follow any business specific guidelines on antitrust and competition law issued by the FedEx Legal Department.

Related Policies

• FedEx Code of Conduct

Policy Compliance

Strict compliance with this Policy is required. Compliance also includes timely completing any mandatory training and following any procedures that may be issued under this Policy.  All members of management are responsible within their teams for enforcement and compliance with this Policy, including its communication to their Team Members.  Any Team Member who does not comply with this Policy shall be subject to disciplinary action, up to and including termination, to the extent permissible under local law.

Reporting and Anti-Retaliation Policy

We encourage Team Members to speak up and report violations of this Policy.  If you have information about a possible violation of this Policy, contact your management, your Legal or Human Resources department or the FedEx Alert Line.

Reports to the FedEx Alert Line may be made anonymously by calling a toll-free number or completing an online report form.  Within the U.S., you can reach the FedEx Alert Line at 1-866-42-FedEx (1-866-423-3339).  International phone numbers and access to the online report form can be found at www.fedexalertline.com.

We prohibit retaliation against anyone who reports a known or suspected violation in good faith.  We also prohibit retaliation against anyone who assists in an investigation.  Any Team Member who is found to have retaliated against a person who has reported in good faith a violation, or assisted in an investigation, will be subject to discipline, up to and including termination to the extent permissible under local law.

Policy Custodian

Chief Compliance Officer

Adoption Date

This Policy was adopted May 15, 2013.

Last Amended June 1, 2020.

Introduction

Overview

Since FedEx began operations in 1973, respect for people has been the cornerstone of how we do business. Our company’s commitment to integrity and doing the right thing is a fundamental part of who we are, as reflected in our company culture, values, and the FedEx Code of Conduct. As such, we strive to exemplify ethical leadership and corporate responsibility through support of Human Rights on a global scale.

Purpose

This Policy communicates our Human Rights standards to FedEx team members and stakeholders, provides a common model of how to support and advance Human Rights in our everyday operations, and reinforces our expectations that all team members treat others with dignity and respect.

Definitions

FedEx: FedEx Corporation and its subsidiary companies throughout the world.

Human Rights: Generally defined as the basic freedoms and principles of equality and fairness which are inherent to all people everywhere and worthy of universal protection. Rights that exist simply because we are human beings. These rights are outlined in the United Nations Universal Declaration of Human Rights (UDHR).

Team Member: Every officer, director, manager, and employee of FedEx.

Third Party: Any prospective or current customer, vendor, supplier, service provider or any other person with whom FedEx does or may do business and which is not a FedEx entity.

Scope

This Policy applies to every team member of FedEx. If you have questions about a situation not covered in this Policy, you should ask your manager, Human Resources, or the Legal Department.

This Policy also applies to those Third Parties performing services on behalf of FedEx or operating under the FedEx brand name to the extent set forth in their respective agreements with FedEx and permitted under applicable law. Failure to abide by this policy may result in consequences, including but not limited to the termination of a business relationship with FedEx.

This Policy complements and connects the related policies mentioned below but is not meant to supersede them. FedEx subsidiary companies may adopt supplementary policies, if necessary to comply with local laws and regulations. Subsidiaries shall provide the Corporate Integrity and Compliance (CIC) Department a copy of any such supplementary policy before publication.

Policy Statement

FedEx is committed to operating our business in a manner which protects and advances Human Rights in all our operations around the world. We care about people, our communities, and the impact we have, wherever we do business. We believe that everyone, from every background and ability, should have access to opportunity, the chance to make choices about their lives, and a path to develop their potential as human beings.

We expect every team member to consistently behave in alignment with our values and in compliance with law and policy. In our operations globally, we will work to treat people with fairness and respect. The respective standards are outlined in our Code of Conduct. We also work to contract with suppliers who respect Human Rights. We expect our supply chain to embrace and pursue business practices consistent with our standards for supporting Human Rights as outlined in the FedEx Supplier Code of Conduct.

Policy Details

Respect for Human Rights

At FedEx, delivering for good includes supporting the development and implementation of business practices which advance Human Rights. We endeavor to understand how our operations may positively or negatively impact people, and to act considerately and make decisions that are respectful of people and communities. We seek the input of diverse stakeholders and take steps to incorporate our values into our operations and activities within the communities where we work.

Governance

Oversight of this Policy is vested in our Chief Compliance Officer (CCO). Our CCO leads our Corporate Integrity and Compliance Department globally. CIC collaborates with our global team members in Legal and Compliance to develop and support policies, programs, and practices in this area. The CCO reports up through the FedEx General Counsel and provides regular updates to the Audit and Finance Committee and to the full Board of Directors on the FedEx compliance program initiatives and risks. The CCO also provides oversight of our FedEx Supplier Code of Conduct, which informs suppliers of our requirements for legal compliance, ethical behaviors, and respect for Human Rights.

Team Member Requirements

We expect our team members to comply with the law and to consistently demonstrate behaviors which show respect for the inherent dignity of people. FedEx prohibits Human Rights violations in our operations. No person should be subject to a Human Rights violation because of the work we do at FedEx. Managers have additional requirements for providing ethical leadership which are also enumerated in our Code of Conduct. Similarly, FedEx strives to avoid contributing to the infringement of the Human Rights of others everywhere we do business.

Respect for Human Rights is addressed in our Code of Conduct and in our complete policy framework. Team members must follow the law, the direction provided in this Policy, our Code of Conduct, and our other policies and procedures. Key topics from these policies are summarized below. For more details, review the FedEx policies and procedures in effect for each topic. Related policies can be accessed here, or you can ask your manager, Human Resources, or the Legal Department for additional information on any of these topics.

Anti-Harassment and Non-Discrimination

We uphold equal opportunity and oppose harassment. We do not tolerate discrimination, harassment, or bullying based on any characteristic protected under national, state, or local laws. We strongly encourage team members who may be subject to or witness harassment in the workplace to speak up without fear of retaliation. We strive to create a workplace where people feel safe and free from bullying or harassment.

Diversity, Equity, Inclusion and Opportunity

Diversity, Equity, Inclusion and Opportunity are cornerstone beliefs which we put into practice at FedEx. We are committed to taking measurable actions to empower diverse voices and provide equitable access to leadership, education, and employment opportunities. Team members at FedEx are governed by a common set of values and ethics, and we believe in a global community where people are respected and valued.

Health, Safety and Security

At FedEx, we all must follow health and safety rules and protocols that apply to our jobs. FedEx prohibits workplace violence, including violent or threatening behavior. We also do not allow other activities that could cause a person to feel unsafe, insecure, or fearful. We are committed to maintaining a healthy, safe, and secure workplace.

Anti-Corruption

Corruption and Human Rights violations are strongly associated with each other. FedEx recognizes that in addition to being illegal and unethical, corruption can violate Human Rights principles involving fairness, non-discrimination, and the rights of people to have a meaningful impact and opportunities.

Corruption can impede the realization of a fair society and cause direct harm to communities and people. FedEx prohibits corruption and improper payments in all our business dealings throughout the world. We have strict policies and procedures, training, and other programs to help prevent, detect, and address corruption. Our Global Anti-Corruption Policy provides a framework for our rules prohibiting corruption.

Labor and Employment, and Wage and Hour Laws

Compliance with labor and employment laws is a high priority at FedEx. We strive to show respect for our team members and communities by staying informed on and complying with laws that govern employment relationships. Treating people fairly includes paying fair wages and following labor and employment laws in the countries and territories where we operate.

Prohibition of Forced Labor, Human Trafficking and Child Labor

We have zero tolerance for, and prohibit human slavery and trafficking, child labor, or any other form of forced labor. FedEx team members must comply with this Policy, the Code of Conduct, the Policy Prohibiting Trafficking in Persons, and all applicable local policies which may be in effect in the FedEx region, country or territory where they work.

Privacy

We recognize the importance of privacy protections and compliance with applicable data privacy laws, regulations, internal policies, and standards. These protections form the foundation of a trustworthy company and help promote compliance with law. Our Global Privacy Policy addresses these protections and is based on globally accepted core principles on data protection.

Policy Implementation

Training and Communication

We set expectations and standards for our team members. We use training and communication programs to create foundational awareness and to reinforce key concepts. FedEx policies are posted online and translated into dozens of our most used languages. The CIC team periodically refreshes and communicates policy requirements. We provide training and communication on policies to reinforce behavioral expectations and to help embed and sustain a culture of respect for Human Rights throughout the business.

We provide resources to Managers to support communication of key compliance requirements and programs to their team members who work in non-computer using positions or offline. We incorporate messaging on Human Rights into our communication plans to raise awareness with our team members, communities, and other stakeholders of the importance of respecting Human Rights in our operations.

Risk Assessment

In addition to providing behavioral standards for our team members and communication and training on our Human Rights Policy, we strive to avoid contributing to the infringement of the Human Rights of others everywhere we do business. As part of our ongoing risk assessment processes, we seek to identify, assess, quantify the impact, and address the risk of Human Rights violations in our operations in line with applicable laws and regulations. We pursue continuous improvement where we periodically assess our approach to compliance and ensure we evolve our practices alongside our business.

Monitoring and Reporting

Communicating with our stakeholders on Human Rights in our operations is a matter of transparency. Structured public reporting provides an opportunity for us to understand and be accountable for adverse Human Rights impacts we encounter, or which may be present in our business. CIC works with our Financial Reporting and Environment, Social and Governance (ESG) teams, to report on our business, Human Rights related risks, and measures we take to address those risks. Our careful identification, assessment, prevention, mitigation, and remediation of risk is aligned with our policy of respect for Human Rights.

International Human Rights Standards

In support of the responsibility of governments to protect Human Rights, businesses have a unique opportunity to make a positive impact. As a global business, we strive to respect international Human Rights standards. This Policy provides a globally relevant position statement on our support for advancing Human Rights in our operations.

Protecting and advancing Human Rights also includes compliance with relevant local laws and regulations. The complexity of local or national conditions on Human Rights does not lessen the need and responsibility for global businesses like FedEx to treat all people with dignity and respect.

Policy Compliance

FedEx requires team members to comply with this Policy. Compliance also includes timely completing any mandatory training and following any procedures that may be issued under this Policy. All managers are responsible within their teams for enforcement and compliance with this Policy, including its communication to their team members. Anyone who does not comply with this Policy may be subject to disciplinary action, up to and including termination.

Reporting and Anti-Retaliation

If you know or suspect there is a violation of this Policy, you should speak up and report it to your manager, Human Resources, the Legal Department, or the FedEx Alert Line. You  may submit a report online at fedexalertline.com or find the phone number that applies to a country or territory. In the U.S., the phone number is 1.866.42.FedEx (1.866.423.3339). When making a report, you can choose to identify yourself or, where allowed by law, you can report anonymously.

We prohibit retaliation against anyone who reports a known or suspected violation in good faith. We also prohibit retaliation against anyone who assists in an investigation. Anyone who is found to have retaliated against a person who, in good faith, has reported a violation of this Policy, or assisted in an investigation, will be subject to discipline, up to and including termination.

Related Policies

• FedEx Code of Conduct
• FedEx Supplier Code of Conduct
• Global Anti-Corruption Policy
• Policy Prohibiting Trafficking in Persons

Approvals

Department: Corporate Integrity and Compliance

Policy Custodian: Chief Compliance Officer

Policy Adopted Effective: 16 December 2024

Policy Statement

As stated in the FedEx Code of Business Conduct and Ethics, lawful and ethical behavior is critical to our continued success and is required. You must comply with those laws and regulations relating to your business conduct. In addition, you must avoid and report any activity that involves, or could lead to the involvement of, FedEx in any potentially unlawful practice.

FedEx is committed to protecting and advancing human rights in all of our operations. We treat others with respect and dignity, encourage diversity and diverse opinions, provide safe working conditions, and promote equal opportunity for all.

FedEx supports the policies adopted by the United States government to combat the trafficking of persons for any purpose. As set forth in the following pages, FedEx prohibits trafficking-related activities, and we expect our suppliers and contractors to uphold these important principles, as well. FedEx encourages you to report any suspected violations. If you have reason to believe that a legal or ethical violation has occurred, it is your duty to report it to your manager, Company Contact or the Legal or Human Resources Department, or by using the FedEx Alert Line. Our policies forbid any form of retaliation against you for fulfilling this obligation.

Prohibited Activities

FedEx prohibits all activities relating to the trafficking of persons. You may NOT:

1. Engage in severe forms of trafficking in persons;

2. Procure commercial sex acts;

3. Use forced labor;

4. Destroy, conceal, confiscate, or otherwise deny access by an employee to the employee’s identity or immigration documents, such as passports or drivers' licenses, regardless of issuing authority;

5. (i) Use misleading or fraudulent practices during the recruitment of employees or offering of employment, such as failing to disclose, in a format and language accessible to the worker, basic information or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if employer or agent provided or arranged), any significant cost to be charged to the employee, and, if applicable, the hazardous nature of the work; (ii) Use recruiters that do not comply with local labor laws of the country in which the recruiting takes place;

6. Charge employees recruitment fees;

7.  (i) Fail to provide return transportation or pay for the cost of return transportation upon the end of employment­–

• For an employee who is not a national of the country in which the work is taking place and who was brought into that country for the purpose of working on a U.S. Government contract or subcontract (for portions of contracts performed outside the United States); or
• For an employee who is not a United States national and who was brought into the United States for the purpose of working on a U.S. Government contract or subcontract, if the payment of such costs is required under existing temporary worker programs or pursuant to a written agreement with the employee (for portions of contracts performed inside the United States); except that­–

(ii) The requirements of paragraphs (b)(7)(i) of this clause shall not apply to an employee who is–

• Legally permitted to remain in the country of employment and who chooses to do so; or
• Exempted by an authorized official of the contracting agency from the requirement to provide return transportation or pay for the cost of return transportation;

(iii) The requirements of paragraph (b)(7)(i) of this clause are modified for a victim of trafficking in persons who is seeking victim services or legal redress in the country of employment, or for a witness in an enforcement action related to trafficking in persons. The contractor shall provide the return transportation or pay the cost of return transportation in a way that does not obstruct the victim services, legal redress, or witness activity. For example, the contractor shall not only offer return transportation to a witness at a time when the witness is still needed to testify. This paragraph does not apply when the exemptions at paragraph (b)(7)(ii) of this clause apply.

8. Provide or arrange housing that fails to meet the host country housing and safety standards; or

9. If required by law or contract, fail to provide an employment contract, recruitment agreement, or other required work document in writing. Such written work document shall be in a language the employee understands. If the employee must relocate to perform the work, the work document shall be provided to the employee at least five days prior to the employee relocating. The employee’s work document shall include, but is not limited to, details about work description, wages, prohibition on charging recruitment fees, work location(s), living accommodations and associated costs, time off, roundtrip transportation arrangements, grievance process, and the content of applicable laws and regulations that prohibit trafficking in persons.

Reporting

If you know of or suspect there is a violation of this Policy, you must immediately report it to your manager, Company Contact or your company’s Legal or Human Resources Department or use the complaint processes within your operating company. FedEx policies prohibit any form of retaliation against a person who reports in good faith any known or suspected misconduct.

In addition to the people above, you may report suspected human trafficking activities to:

The FedEx Alert Line:
1.866.42.FedEx (1.866.423.3339)
www.fedexalertline.com

The Global Human Trafficking Hotline:
1.844.888.FREE (1.844.888.3733)
help@befree.org