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.

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