Global Policy on Reporting Concerns

Policy Custodian: FedEx Chief Compliance Officer
Policy Adopted Effective: 1 May 2022

Policy Overview

At FedEx, we are committed to behaving ethically, with integrity, and in compliance with the law. Our fellow team members, customers, communities, and the marketplace expect nothing less of us. To help us maintain the highest standards of business ethics, it is important for our team members to speak up and raise questions and concerns about potential integrity, compliance, environmental, health, or safety issues. Unethical, illegal, unsafe, or other improper actions conflict with our core values and can harm our company, reputation, team members, and customers. When you speak up, you support our ethical culture and protect others by allowing FedEx to address the concern.

Scope

Overview
This Policy applies to every officer, director, and employee (collectively, “team member”) of FedEx Corporation and its subsidiary companies throughout the world (“FedEx”). If you have questions about a situation not covered in this Policy, you should ask your manager or your Legal or Human Resources Department. Third parties (e.g., vendors/suppliers and their employees, stockholders, customers, and other non-team members) may also elect to use the reporting channels identified in this Policy to report concerns.

Local Policies and Procedures
Various countries have whistleblower laws that impose 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 those laws have appropriate channels, adequate information on the topic, required data protection, and protection from retaliation. While this Policy provides globally applicable guidance on reporting concerns and non-retaliation, each FedEx Operating Company or International Region may also implement local policies or procedures to comply with local laws or to effectively implement this Policy.

Non-Retaliation

FedEx supports an environment where you can raise concerns without fear of retaliation and with confidence that the matter will be addressed. Every team member is responsible for reporting suspected misconduct. Reports received by FedEx are handled professionally, treated confidentially, and appropriately investigated.

FedEx prohibits retaliation against anyone who reports a known or suspected violation in good faith (you reasonably believe the violation is true when you report it). FedEx also prohibits retaliation against anyone who assists in an investigation. Anyone who is found to have retaliated against a person who has reported a violation in good faith or assisted in an investigation will be subject to discipline, up to and including termination.

Reporting Concerns

What Should be Reported
You should report misconduct that violates the FedEx Code of Conduct, or any other unsafe, unethical, or unlawful behavior. Some examples of wrongdoing that require reporting under this Policy include bribery; corruption; conflicts of interest; environmental, health, and safety violations; and any other violations of FedEx policy or the FedEx Code of Conduct.

Reporting Issues Related to Financial Fraud, Accounting, or Auditing Matters
Any team member who learns of issues related to financial fraud or accounting, internal accounting controls, or auditing matters should always report these issues to the FedEx Alert Line or 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 reasonably suspected or known. If you cannot report an issue when it is reasonably suspected or known, you should still make a report no matter how much time has passed.

How to Report a Concern
For team members, concerns may be reported to your manager; other members of FedEx management; the Human Resources, Security, Legal, or Corporate Integrity and Compliance departments; or the FedEx Alert Line. While we encourage concerns to first be raised with your manager, concerns can be raised through any of the available channels. Financial fraud, accounting, internal accounting controls, or auditing matters should always be reported through 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.

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

What Happens After You Report a Concern?
Once received, reports undergo an initial assessment to determine whether an investigation is appropriate. If it is determined that an investigation is necessary, the investigation will be assigned to the appropriate FedEx team member(s) or third party to handle. The investigator may contact you for additional information and you are encouraged to cooperate with investigators to the fullest extent possible.

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 channels for reporting.

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 to your team members that they can come to you with concerns. 
• Are accessible and available. 
• Listen attentively. Ask questions. 
• Respect team members’ concerns. 
• Handle the concern or refer and track the issue as needed.

Human Resources, Legal, or Corporate Integrity and Compliance Department
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 Legal department, or to the Corporate Integrity and Compliance Department at integrity@fedex.com.

Security Department
The FedEx Security Department is also an option for reporting certain issues, such as theft, workplace violence, and security/facility breaches. You should report workplace violence directly with Security using an online incident form at https://esims01.prod.cloud.fedex.com:8004/esims-webapp/wpvp. You can also email Security at asksecurity@corp.ds.fedex.com or call the Global Security Operations Team at 1-800-872-8025 or 901-922-1945. Team members can also report security concerns to local Security team members.

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 questionnaire. Both the telephone hotline and online reporting are available 24 hours a day, 7 days a week virtually anywhere in the world.

Based on variations in international law, reporting in some countries 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 to your manager or another member of management, the Human Resources or Legal Department, or the Corporate Integrity and Compliance Department.

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 prohibit anonymous reporting) and you may request to remain anonymous when making reports through channels other than the Alert Line. FedEx strictly prohibits any attempt to discover the identity of reporters who request to remain anonymous. However, we encourage you to reveal your identity, as it is often difficult to investigate certain anonymous reports. Providing contact information also allows us to communicate with you directly about your report.

Reports will also be kept confidential, although FedEx may have to share the report with others to sufficiently investigate or address the concern.

In certain countries, FedEx may be required to inform the implicated person(s) when a complaint has been filed against them. However, we do not disclose your identity to the implicated party unless required by law to do so. Similarly, all persons 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.

Related Policies

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

Policy Compliance

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 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 shall be subject to disciplinary action, up to and including termination.

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