Modern Slavery Act 2015 – Compliance Statement for 2016
Lawful and ethical behaviour is of paramount importance to FedEx and is critical to our continued success. The FedEx Code of Business Conduct and Ethics makes it clear that is a requirement for all of our employees and places similar obligations upon suppliers to FedEx. As part of this requirement FedEx is committed to protecting and advancing human rights in all of our operations wherever they may be in the world.
FedEx is fully supportive of the laws introduced within the United Kingdom in particular through the Modern Slavery Act 2015 (to combat slavery, forced or compulsory labour and the trafficking of persons for any purpose (‘Slavery and Human Trafficking’).
This statement outlines the steps that FedEx takes to combat all forms of Slavery and Human Trafficking.
Within the United Kingdom FedEx provides international and domestic delivery services and mainly operates through two companies, Federal Express Europe Inc (‘FedEx Express’) and FedEx UK Limited (‘FedEx UK’).
FedEx Express is a global leader in express distribution providing rapid, reliable, time definite delivery to more than 220 countries and territories connecting markets that compromise more than 90 percent of the world’s gross domestic product within one to three business days.
FedEx UK is a provider of a range of delivery and logistics services within the United Kingdom though an established national pick-up and delivery network.
FedEx also provides services within the United Kingdom through other subsidiaries of FedEx Express including supply chain solutions through FedEx UK Supply Chain Services Limited and FedEx Supply Chain Services UK Limited*. For the purposes of this statement the companies operating within the United Kingdom are collectively referred to as FedEx.
Our Supply Chains
As a global transportation company FedEx has a large and complex supply chain and has many direct supply arrangements on a global basis and on an individual in country basis. Key supplies for a company like FedEx include for fuel (for aircraft and motorized vehicles), packaging, equipment and personnel (for example temporary/agency staff).
The FedEx Code of Business Conduct and Ethics sets out the expectations that are relevant for all of our employees and for our suppliers wherever we do business in the world. Doing business in an ethical and responsible manner is already enshrined within our current set of policies and procedures. These policy and procedures help to ensure that Slavery and Human Trafficking does not occur within FedEx or its supply chains. Policies that are relevant to this include:
- Lawful and Ethical Behaviour Policy
- Equal Opportunity and Anti-Harassment Policies
- Open Door Policy
- Health, Safety & Environment Policy
- Human Rights Policy
- Code of Business Conduct
- Bullying and Harassment Policy
- Whistleblowing Policy
FedEx maintains a strong culture of ethics and integrity that supports and encourages compliance with these internal policies. Open Door and Whistleblowing policies, as well as the FedEx Alert Line, allow FedEx employees or other concerned parties to raise concerns about any business conduct without fear of reprisal or retribution. Such compliance is further supported by a strong Internal Audit function which regularly conducts audits of all areas of our business and works closely with the internal Legal Department to ensure full compliance with all applicable laws and regulations.
FedEx continually strives to enhance its approach and its internal policies and procedures have been reviewed in light of the changes in laws in Slavery and Human Trafficking. In the United Kingdom, a cross functional internal team has been formed to review this issue and consider what additional enhancements may be beneficial. Local management has been briefed on the new legal obligations and a supplemental policy to reinforce and reiterate the position with regarding to Slavery and Human Trafficking has been developed. Globally, FedEx has implemented a Policy Prohibiting the Trafficking of Persons and is communicating the policy and guidance to relevant management worldwide.
FedEx seeks to source its supplies in a responsible manner and fully expects and requires its Suppliers to operate in full compliance with all applicable laws. A failure by a Supplier to comply with applicable laws (including as they relate to Slavery and Human Trafficking) would be a justifiable reason for such relationship to be terminated.
Given the nature of our transportation business model, FedEx does not currently believe that there is a significant risk of Slavery and Human Trafficking within the supply chain. We will, however, continue to review our Supplier engagement policies, contractual approach and due diligence process to improve our program and mitigate risks of slavery and human trafficking in this area, which is an area of greater relative risk. Given the Global nature of our business we will liaise with our central Corporate Integrity and Compliance team to act on a Global scale. Consideration will also be given as to how it is possible to try and track the effectiveness of compliance in this area.
FedEx will continue to build upon the robust compliance culture that it has in place and seek to maintain its high standards and identify ways to further enhance this.
This statement is signed on behalf of the Board of Directors by Trevor Hoyle, Senior Vice President (FedEx Express & TNT) Operations Northern Europe.
Governance and Citizenship. Further information can be found at:
* At the close of the reporting cycle covered by this Compliance Statement, FedEx acquired TNT, which also provides services within the UK. As integration of the operations of FedEx and TNT occurs, the companies’ compliance efforts related to the Modern Slavery Act will likewise be integrated and ultimately reported together.