Ways to speak up

Introduction

Purpose

At FedEx Corporation and its subsidiary companies throughout the world (“FedEx”), we are dedicated to operating ethically, with integrity, and in compliance with the law. Our fellow officers, directors, managers, and employees (each, a “team member” and collectively, “team members”), customers, suppliers, communities, and investors expect nothing less from us. To uphold the highest standards of business ethics, it is crucial for our team members to speak up and raise questions and concerns about potential issues involving integrity or compliance, Misconduct, and safety. When you speak up, you support our ethical culture and help protect others by allowing FedEx to address the concerns.

Overview

This Policy establishes each team member’s responsibility to report suspected Misconduct. FedEx manages and investigates such reports professionally, confidentially, and appropriately. At FedEx, team members can raise concerns without fear of retaliation, and with confidence the matter will be addressed.

Scope

This Policy applies to every team member of FedEx. Third parties (e.g., vendors/suppliers and their employees, customers) may also use the reporting channels identified in this Policy to report concerns.

Some countries or territories have whistleblower laws imposing requirements on companies related to receiving and handling reports from employees or others about certain types of conduct. We are committed to ensuring those who raise concerns covered under these laws have appropriate reporting channels, sufficient information on the topic, required data privacy protection, and protection from retaliation. While this Policy provides globally applicable guidance on reporting concerns and non-retaliation, each FedEx subsidiary or international region may also implement policies or procedures to comply with local laws or to effectively implement this Policy.

Definitions

    Accounting & Auditing Matter: Any Misconduct (defined below) related to financial fraud or questionable accounting, internal controls, or auditing.

    Good Faith Report: Any report by an individual who reasonably believes the facts shared are true at the time of the report.

    Misconduct: Any conduct which may violate the FedEx Code of Conduct, any FedEx policy, any law, or any regulation, or involves unethical behavior.

    Policy: This Global Policy on Reporting Concerns.

Policy Details

What to Report

All FedEx team members are expected to report known or reasonably suspected Misconduct.

Reporting Accounting & Auditing Matters

If you become aware of an Accounting & Auditing Matter, you must report it. Accounting & Auditing Matters include, without limitation:

• Fraud or deliberate error in the preparation, evaluation, or audit of any FedEx financial statements or the recording and maintaining of FedEx’s financial records;
• Deficiencies in or noncompliance with FedEx’s internal accounting controls;
• Misrepresentations or false statements to or by a senior officer or accountant regarding a matter contained in FedEx’s financial records or audit reports; or
• Deviation from the full and fair reporting of FedEx’s financial condition.

Team members must report such Misconduct using the FedEx Alert Line or to the FedEx Corporation General Counsel under the FedEx Policy on Treatment of Complaints Regarding Financial Fraud and Accounting and Auditing Matters.

When to Report a Concern

You should report a concern as soon as an issue is suspected or known. If you did not report an issue when it was suspected or known, you should still report no matter how much time has passed.

How to Report a Concern

FedEx provides many different channels to report concerns. While team members are encouraged to first raise concerns to their direct manager, concerns may be reported to other members of FedEx management; to any of the Human Resources, Security, Legal, or Corporate Integrity and Compliance (CIC) departments; or via the FedEx Alert Line.

Third parties who wish to report a concern should contact their FedEx business representative (for vendors/suppliers and customers), the Legal or CIC departments, or the FedEx Alert Line.

What Happens After You Report a Concern?

Once received, each report undergoes an initial assessment to determine whether an investigation is appropriate. If an investigation is necessary, the investigation will be assigned to the appropriate FedEx team member(s) or third party to handle. You can expect the investigator to contact you for additional information. FedEx team members have a duty to cooperate with internal investigations, and some third parties have contractually agreed to similarly cooperate with FedEx investigations.

Available Reporting Channels

    Open Door Policy. Your manager is typically in the best position to address your concerns; therefore, we encourage FedEx team members to contact their managers first. If you are not comfortable speaking with your manager about the issue or your manager is not available, we encourage you to utilize any of the other available reporting channels described in this Policy.

FedEx expects managers and other leaders to keep an open door for team members to report concerns. Keeping an open door encourages open communication, trust, feedback, and discussion.

As a manager or leader, “having an open door” means you:

• Communicate with your team members that they can come to you with concerns;
• Are accessible and available;
• Listen attentively. Ask questions;
• Respect team members’ concerns;
• Address the concern or refer and track the issue as needed; and
• Know when to escalate team members’ concerns to other departments.

    Human Resources, Legal, or CIC departments. If you prefer not to report a concern to your manager or another member of management, you may also raise your concern to a member of the Human Resources or the Legal department, or to the CIC department at integrity@fedex.com.

    Security department. The Security department is also an option for reporting certain issues, such as theft, workplace violence, and security or facility breaches. You should report workplace violence directly to the Security department using the keyword: wpvp.  For immediate assistance, contact a local Security team member; call the Global Security Operations Center (GSOC) at 1-800-872-8025; or dial 911 in case of emergency. You can also email GSOC at asksecurity@corp.ds.fedex.com.

    FedEx Alert Line. Concerns can also be reported to the FedEx Alert Line by calling a toll-free telephone number or by completing an online form. Both the telephone hotline and online reporting are available 24 hours a day, 7 days a week virtually anywhere in the world and do not require FedEx network or credentials to access.

Based on variations in international law, reporting in some countries and territories may be limited to only certain types of matters. If you cannot submit an Alert Line report based on these limitations, you can still report the concern using the other reporting methods in this Policy.

You can reach the FedEx Alert Line in the United States at 1-866-42-FedEx (1-866-423-3339). If you are outside the U.S., click here for phone numbers. Reports may also be made online at fedexalertline.com.

Anonymity, Confidentiality, and Privacy

The FedEx Alert Line allows for anonymous reporting (unless the laws of your country or territory prohibit anonymous reporting). However, we encourage you to reveal your identity as it is often difficult to investigate certain anonymous reports. Providing contact information allows us to easily communicate with you about any additional information needed to effectively investigate your concerns.

Whether you choose to identify yourself or submit anonymously, all reports of Misconduct are treated confidentially. This means the information you provide will only be shared with a limited number of people on a “need-to-know” basis to sufficiently investigate or address the concern.

In certain countries and territories, FedEx may be required to inform the implicated person(s) when a complaint has been filed against them. However, we do not disclose who reported an issue to the implicated party unless required by law to do so. Similarly, all people involved in an investigation—even the implicated party—are entitled to confidentiality to protect their privacy, legal rights, and reputation.

FedEx is committed to protecting the privacy of everyone involved in a reported concern of Misconduct, safeguarding personal data from unauthorized access or use, and complying with applicable data protection laws.

Review Period

The Policy Owner will review this Policy at least once every two fiscal years to ensure relevance, applicability, and alignment with any legal or regulatory obligations of FedEx or management decisions that could affect this Policy.

Attestation

Team members may be required, from time to time, to attest that they have received a copy of this Policy, understand it, and comply with it.

Policy Compliance

Compliance with this Policy is required. Compliance also includes timely completion of 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 will 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, speak up and report it to your manager; to any of the Human Resources, Legal, or CIC departments; or via the FedEx Alert Line.

Go to fedexalertline.com to report online or find the phone number that applies to your country or territory. We prohibit retaliation against anyone who makes a Good Faith Report of a known or suspected violation. We also prohibit retaliation against anyone who assists in an investigation.

Anyone who is found to have retaliated against a person who made a Good Faith Report of a violation of this Policy, or assisted in an investigation, will be subject to discipline, up to and including termination.

Related Policies and Procedures

• FedEx Code of Conduct
• Policy on Treatment of Complaints Regarding Financial Fraud and Accounting and Auditing Matters
• FedEx Investigator Code of Ethics
• Your Company’s Whistleblowing Policy or Procedures
• Your Company’s Open-Door Policy

Approvals

Department: Corporate Integrity and Compliance

Policy Owner: Chief Compliance Officer

Policy Adoption Date: May 1, 2022

Policy Updated Effective: June 25, 2025

Policy Statement

Purpose

The purpose of this policy is to set forth the procedures established by the Audit and Finance Committee of the FedEx Corporation Board of Directors for:

1. the receipt, retention, and treatment of complaints or concerns received by FedEx Corporation and its subsidiaries (collectively, “FedEx”) regarding financial fraud or accounting, internal accounting controls, or auditing matters; and
2. the confidential, anonymous submission by FedEx’s employees and contractors throughout the world of complaints or concerns regarding financial fraud or questionable accounting or auditing matters.

Complaints and Concerns Covered by Policy

The procedures set forth in this policy relate to complaints and concerns regarding:

1. financial fraud or questionable accounting, internal accounting controls, or auditing matters, including, without limitation:
   • fraud or deliberate error in the preparation, evaluation, review, or audit of any FedEx financial statement;
   • fraud or deliberate error in the recording and maintaining of FedEx’s financial records;
   • deficiencies in or noncompliance with FedEx’s internal accounting controls;
   • misrepresentation or false statement to or by a senior officer or accountant regarding a matter contained in FedEx’s financial records, financial reports, or audit reports; or
   • deviation from the full and fair reporting of FedEx’s financial condition; or
2. retaliation against employees or contractors who, in good faith, make reports regarding any of the foregoing items.

Any of the above complaints or concerns are considered a Report under this policy.

Responsibilities with Respect to Specified Reports

The Audit and Finance Committee is responsible for overseeing the receipt, retention, and investigation of and response to all Reports. The FedEx Corporation Executive Vice President, General Counsel and Secretary (the “General Counsel”) and Staff Vice President – Chief Compliance Officer (“CCO”) are responsible for administering these procedures on behalf of FedEx.

The General Counsel or CCO will promptly forward to the Audit and Finance Committee any Report involving a FedEx senior officer or having a potential aggregate value exceeding $1,000,000. In determining whether the Audit and Finance Committee, the General Counsel, or CCO should be responsible for investigating such Report, the Audit and Finance Committee will consider all relevant facts and circumstances, including the identity of the alleged wrongdoer, the gravity of the alleged wrongdoing, and the likelihood of a material adverse effect on FedEx’s reputation or financial statements.

The General Counsel or CCO (or his or her respective designee) will investigate all other Reports. At the next scheduled Audit and Finance Committee meeting, the General Counsel or CCO will present a summary of all other Reports received. The General Counsel or CCO will provide such additional information regarding any Report as may be requested by the Audit and Finance Committee.

Treatment of Reports

In connection with the investigation of a Report, the Audit and Finance Committee, the General Counsel, and CCO may consult with, and obtain the assistance of, any member of FedEx management who is not the subject of the Report. Additionally, independent legal, accounting, or other advisors may be retained as necessary or appropriate.

Upon completion of the investigation of a Report, the General Counsel or CCO (or his or her respective designee) will update the Audit and Finance Committee of the outcome and prompt and appropriate corrective action shall be taken if the Report is substantiated.

Follow-Up to Reports

The Audit and Finance Committee, General Counsel, or CCO (or a designee) will update, to the extent appropriate and practicable, each person who files a Report to inform him or her of the status of the investigation.

Retaliation Prohibited

Consistent with FedEx’s policies, neither FedEx, the Audit and Finance Committee, nor any director, officer, or employee of FedEx will retaliate, directly or indirectly, against any FedEx employee or contractor who makes a Report in good faith or otherwise assists FedEx or any other person or group investigating a Report, including any governmental, regulatory, or law enforcement body.

Neither FedEx, the Audit and Finance Committee, nor any director, officer, or employee of FedEx will (i) reveal the identity of any person who makes a Report and asks that his or her identity remain confidential, unless compelled by judicial or other legal process, or (ii) make any effort to ascertain the identity of any person who makes a Report anonymously.

Records

The CCO will maintain a log of all Reports, tracking their receipt, investigation, and resolution and the response to the person making the Report.

FedEx will retain all Reports and all records relating to such Reports in accordance with the applicable provisions of its records retention policy.

Procedures for Making Reports

The FedEx Alert Line is managed by an outside, independent service provider and allows any FedEx employee or contractor to make a Report without divulging his or her name. The FedEx Alert Line service provider is required to share promptly the information provided in the Report with the General Counsel, CCO, or his or her respective designee and the FedEx Corporation Internal Audit Department. The FedEx Alert Line service provider supplies instructions to individuals making a Report on how to follow-up and check on the status of a Report.

Reports can be made confidentially and anonymously, 24 hours a day, seven days a week as follows:

1. by calling the FedEx Alert Line, toll-free, at 1.866.42.FedEx (1.866.423.3339)
   (phone numbers for callers outside the United States or Canada are available at www.fedexalertline.com);
   
2. by submitting an online report via the FedEx Alert Line web portal located at www.fedexalertline.com; or
3. by writing to FedEx management at the following address:

FedEx Corporation
Attn: Executive Vice President, General Counsel and Secretary
942 South Shady Grove Road
Memphis, Tennessee 38120

Additional information on making a Report and raising other concerns is provided in FedEx’s Global Policy on Reporting Concerns.

Amended March 3, 2023

Department of Justice
Office of the Inspector General
WHISTLEBLOWER INFORMATION
for
DEPARTMENT of JUSTICE CONTRACTORS,
SUBCONTRACTORS, AND GRANTEES

Employees of Department of Justice contractors, subcontractors, and grantees perform an important service by reporting what they reasonably believe to be evidence of wrongdoing.

Whistleblowers perform an important service to the Department of Justice (DOJ) and the public when they come forward with what they reasonably believe to be evidence of wrongdoing. They should never be subject to reprisal for doing so.

Federal law protects federal employees against reprisal for whistleblowing. In addition, under the National Defense Authorization Act of 2013 (NDAA), it is illegal for an employee of a Federal contractor, subcontractor, or grantee to be discharged, demoted, or otherwise discriminated against for making a protected whistleblower disclosure. Also, under Presidential Policy Directive (PPD-19), an action affecting access to classified information cannot be taken in reprisal for protected whistleblowing.

The Department of Justice Office of the Inspector General (DOJ OIG) has jurisdiction to investigate allegations of reprisal for whistleblowing by employees of DOJ contractors, subcontractors, and grantees. Information on how to report suspected reprisal to the OIG is available at: https://oig.justice.gov/hotline/.

What is a whistleblower?

A whistleblower is an employee of a Federal contractor, subcontractor, or grantee who discloses information that the individual reasonably believes is evidence of:

• Gross mismanagement of a Federal contract or grant;
• A gross waste of Federal funds;
• An abuse of authority relating to a Federal contract or grant;
• A substantial and specific danger to public health or safety; or
• A violation of law, rule, or regulation related to a Federal contract (including the competition for or negotiation of a contract) or grant.

To whom must the disclosure be made to be protected?

To be protected under the NDAA, a disclosure regarding a DOJ contract, subcontract, or grant must be made to one of the following:

• A Member of Congress, or a representative of a committee of Congress;
• The OIG;
• The Government Accountability Office (GAO);
• A Federal employee responsible for contract or grant oversight or management at DOJ;
• An otherwise authorized official at DOJ or other law enforcement agency;
• A court or grand jury; or
• A management official or other employee of the contractor, subcontractor, or grantee who has the responsibility to investigate, discover, or address misconduct.

What can I do if I believe retaliation has occurred?

Employees of contractors, subcontractors, or grantees may file a complaint under the NDAA with the OIG, which will investigate the matter unless the OIG determines that the complaint is frivolous, fails to allege a violation of the prohibition against whistleblower reprisal, or has been addressed in another proceeding. If the OIG finds that retaliation has occurred, it can recommend that the Department order the contractor, subcontractor, or grantee, to take remedial action, such as reinstatement or back pay.

Also, if you are an employee of DOJ or of a DOJ contractor, subcontractor, or grantee and you suspect that a personnel action or an action affecting access to classified information has been taken against you in reprisal for making a disclosure of wrongdoing, you may report it to the OIG.

Nothing in a non-disclosure agreement should be interpreted as limiting your ability to provide information to the OIG.

For further information about whistleblower rights and protections, please see the Whistleblower Protection page on the OIG’s website at: https://oig.justice.gov/hotline/whistleblower-protection.htm

Note: The OIG does not have authority to investigate EEO complaints. For such matters, please refer to the DOJ Equal Employment Opportunity Office, website https://justice.gov/jmd/eeos. If you wish to make a whistleblower disclosure or report reprisal for doing so outside DOJ, you may contact the U.S. Office of Special Counsel, website https://osc.gov.

How can I report wrongdoing to DOJ OIG?

If you know about waste, fraud, abuse, misconduct, or whistleblower reprisal relating to a Department of Justice (DOJ) employee, program, contract, or grant you may report it to the OIG through the following:

Website: https://oig.justice.gov/hotline

Hotline: (800) 869-4499

Fax: (202) 616-9881

Mailing Address:
U.S. Department of Justice
Office of the Inspector General
Inspections Division
1425 New York Avenue, N.W.
Suite 7100
Washington, D.C. 20530-2001

Introduction

Purpose

FedEx is dedicated to ensuring investigations are conducted impartially, fairly, and ethically. FedEx investigators must adhere to certain professional standards when conducting investigations on behalf of FedEx, including those identified in this Code of Ethics. FedEx investigators must also comply with the FedEx Code of Conduct and other FedEx policies and procedures.

Scope

FedEx investigators are authorized through their role or special assignment to conduct investigations on behalf of FedEx. This Investigator Code of Ethics applies to all FedEx investigators when acting in their investigator role at FedEx Corporation and its subsidiaries around the world (“FedEx”). This Policy's applicability to FedEx Europe team members may follow a different timeline pending local labor relations requirements. Please contact your local Legal department or Corporate Integrity & Compliance with any questions.

Code of Ethics

When conducting investigations, FedEx investigators will:

1. Demonstrate integrity and professionalism. This includes interacting with participants in an honest, truthful, and respectful manner.
2. Possess the necessary skills and qualifications to address the subject matter of the investigation. When necessary, supplement their knowledge and consult with subject matter experts.
3. Disclose any conflicts of interest and ensure there are no actual or potential conflicts of interest with any investigative subject matter or participant(s).
4. Use a thorough and objective fact-finding process. This includes reaching conclusions based on truth and fact and avoiding knowingly allowing personal bias, prejudice, or preconceived opinions to interfere with the process.
5. Report findings accurately and completely to ensure conclusions are based on relevant information or other evidence.
6. Ensure all participants, when available and practical, are given a full and fair opportunity to share their perspective.
7. Protect the confidentiality of the investigative process, sharing information on a need-to-know basis only or as required by law.
8. Possess the authorization necessary to conduct the investigation and never knowingly mislead any participant about the nature of the investigation, the investigative process, their authorization, or possible post-investigation actions or outcomes.
9. Safeguard investigative files and evidence collected and retained according to FedEx Global Records & Information Management Policy.
10. Make all reasonable efforts to complete investigations promptly, and ensure results are provided to relevant stakeholders, as appropriate.

Code of Ethics Compliance

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

Related Policies and Procedures

• Code of Conduct
• Global Policy on Reporting Concerns

Approvals

Department: Corporate Integrity & Compliance

Policy Custodian: FedEx Chief Compliance Officer

Policy Adopted Effective:  March 5, 2025