Anti-corruption

Introduction

FedEx is committed to acting with integrity and in compliance with the law. Our Team Members, customers, communities, and other stakeholders trust us to be consistently and reliably compliant in our actions. FedEx prohibits Corruption and Bribery in our business. Corruption and Bribery are wrong, illegal, and against FedEx values. This Policy informs our Team Members of the requirement to act ethically, comply with law and our policies, and report concerns without fear of retaliation. 

 

Policy Overview

The Code of Conduct (the Code) prohibits Corruption and Bribery in all forms. The Code, this Policy, and related programs form the foundation for anti-corruption compliance at FedEx. Our Team Members and those acting on our behalf must not solicit, accept, offer, promise, authorize, or make Improper Payments or Bribes to Government Officials or private persons. FedEx also prohibits Team Members from trading in illegal influence, or Influence Peddling, and from making Facilitation Payments.

To help enforce this Policy and detect potential violations, FedEx has implemented a strong compliance program. Key features of the program include risk assessments, audits, policies and procedures, education, due diligence, monitoring, investigations, reporting, and other controls. 

 

Definitions

•        Anything of value: may include, but is not limited to, cash, gifts, meals, entertainment, travel, employment, paid or unpaid internships, sponsorships, and charitable contributions. The thing of value does not need to be given directly to the Government Official or private person to violate the law. For example, hiring a child of a Government Official in exchange for the official deciding to award business to the company is an “indirect”  thing of value.
•        Bribery or Bribe: anything of value offered, promised, given, solicited, or received in exchange for a favorable decision or improper advantage or exercise of discretion in an official act by a Government Official or private person in order to obtain or retain business.

•        Corporate Integrity and Compliance (CIC): organization led by the FedEx Vice President Chief Compliance Officer that provides the framework, oversight, and legal advice, along with your company’s Legal Department, related to our integrity and compliance programs at FedEx. You can contact CIC at integrity@fedex.com.

•        Corruption: dishonest or fraudulent conduct, including the misuse or abuse of power, influence, or position. Common types include Kickbacks, Bribery, Influence Peddling, and extortion. 

•        Facilitation Payment: anything of value, such as a small payment or gift, offered or provided to a Government Official to expedite their routine clerical or administrative non-discretionary duties. Examples include issuing permits or licenses, starting utility services, clearing a shipment through customs, processing visas, or providing police protection.

•        Government Official: any elected or appointed officer, employee, or other person performing service on behalf of a government at any level (city, county, state, federal, etc.), government agency, state-owned or controlled entity, military, political party, or public international organization. This definition includes a U.S. and non-U.S. Government Official. 

•        Improper Payments: anything of value used to corruptly influence the decision or action of a Government Official or private person/business. Examples include Bribes, Facilitation Payments, and Kickbacks.

•        Influence Peddling: or trading in influence, is using one’s role or connections to dishonestly obtain a favorable decision or exercise of discretion, for another person or entity, in an official act from a Government Official or private person. This act is usually made in exchange for an undisclosed payment or other benefit to the person exercising the influence.

•        Kickback: illegal compensation given in exchange for a favorable action such as influencing the award of a contract. Examples of local terms include graft, cut, and backhander.
•        Legal Department: the legal Team Member or legal team that you work with in your market/country/territory. If you do not know your legal contact, please email integrity@fedex.com.

•        Management: any FedEx Team Member managing at least one other employee. For purposes of the approval process under this Policy, Management or manager refers to the immediate supervisor of the person seeking approval or a more senior member of Management with appropriate decision-making authority.

•        Policy: This Global Anti-Corruption Policy.

•        Promotional Item: goods prominently featuring the FedEx corporate brand or logo. These items are generally available in the company store or catalog.  Examples can include pens, phone chargers, keychains, coffee cups, T-shirts, and badge holders.

•        Team Members: every officer, director, manager, and employee of FedEx Corporation and its subsidiary companies. 

•        Third Party: any prospective or current customer, vendor, supplier, service provider, or any other person or entity outside FedEx with whom FedEx does or may do business. 

Scope

This Policy applies to every officer, director, manager and employee of FedEx Corporation and its subsidiary companies (each, a “Team Member”).

 

Compliance with Law

We comply with the U.S. Foreign Corrupt Practices Act (FCPA), U.K. Bribery Act, French Sapin II, Canadian Corruption of Foreign Public Officials Act, Brazil Clean Companies Act, Swiss Criminal Code, and all other applicable anti-corruption and related laws and regulations wherever we do business.

This Policy provides globally applicable requirements, prohibitions and guidance on anti-corruption compliance. Each FedEx subsidiary or international region may also implement policies or procedures to comply with local laws or to effectively implement this Policy. Supplemental policies, procedures, and other formal guidance on anti-corruption compliance must be provided to, reviewed, and approved by CIC prior to implementation.

 

Policy Details

Corruption, Improper Payments and Bribes are Prohibited

Corruption risk appears in different forms globally. Corruption can be tied to government or private activities and can occur in many situations. FedEx Team Members must be able to recognize situations where prohibited activity, like requests for Bribes or other Improper Payments, may occur.

 

Bribes can be anything of value given with the intent to influence decision making. Bribes come in many forms, including:

• Money, gift cards, gift vouchers, or any other cash equivalent
• Kickbacks
• Unposted fees
• Unwarranted discounts
• Improper Payments disguised as commissions
• Travel, meals, lodging, entertainment
• Charitable and political contributions and sponsorships
• Paid or unpaid jobs and internships
• Goods or services
• Gifts or luxury items
• Items of modest value when given to influence decisions

 

Team Members must uphold our strong opposition to Corruption and Bribery by refusing to approve or participate in corrupt schemes or deals. We must also immediately report suspected Corruption to CIC, your company’s Legal Department, or the FedEx Alert Line.

 

Facilitation Payments are Prohibited

FedEx prohibits Facilitation Payments. These small payments violate the anti-corruption laws of most countries and territories, are not aligned with our values, and encourage Corruption due to lack of documentation and transparency. If you are asked to pay a Facilitation Payment, refuse and immediately notify CIC or your company’s Legal Department.

If a Team Member or a Third Party acting on behalf of FedEx makes a Facilitation Payment in violation of policy, it must be recorded under the Facilitation Payment general account ledger number as indicated later in this Policy. Failure to properly record the payment is a violation of policy and law. If you or a Third Party acting on your behalf makes a Facilitation Payment, you must immediately notify CIC at integrity@fedex.com. CIC will provide you with a Facilitation Payments Documentation Form for completion.

Local fees that are based on officially published local law or regulations, properly documented in writing, and required by a Government Official to perform certain legitimate services are not Facilitation Payments. 

 

Exercising Caution in Customs Clearance

Customs officials may solicit Bribes or other Improper Payments, particularly in high-risk countries and territories. When Team Members have frequent, close interaction with customs officials, they should be properly trained and prepared to quickly refuse and inform the officials that FedEx does not allow such payments. The following are examples of situations where you may be approached for a Bribe or Facilitation Payment: 

• Clearing a shipment through customs; 
• Expediting or avoiding the clearance process or its specific requirements; 
• Avoiding the inspection, detention, or seizure of cargo; 
• Allowing entry, loading, or unloading; 
• Providing required documentation for clearance or creating false documentation for that purpose; or
• Avoiding duties, taxes, or other fees. 

 

Responding to a Request for a Bribe

As a Team Member, if you are asked for or offered a Bribe or Improper Payment, you should: 

• Refuse to make or accept the payment;
• Clearly and firmly object by explaining that FedEx does not allow you to pay or accept Bribes; 
• Be clear that your refusal is not negotiable; and 
• Immediately report the request to Management, CIC, or your company’s Legal Department.

Every Team Member has a responsibility to help recognize, detect, and avoid potential Corruption. 

Travel, Meals, Lodging, Gifts & Entertainment

Team Members must exercise care, know the rules and obtain any required approvals before offering or providing travel, meals, lodging, gifts or entertainment to a Government Official or private person. These actions, if done incorrectly, at the wrong time, too often or in excessive amounts, could be considered a Bribe or Improper Payment.

Knowing the rules and getting advice and approvals in advance will help you understand not only what is prohibited but also what may be appropriate and allowed in each situation.

Before offering or providing travel, meals, lodging, gifts or entertainment to U.S. Government Officials, Team Members must obtain advance, written approval from the FedEx Corporation Government Affairs Department.

Remember to also review the Global Gifts & Entertainment Policy  when offering or receiving gifts to or from Third Parties.

 

Identifying Corruption Red Flags

We must not ignore indicators or red flags of Corruption in our operations or with our Third Parties. Red flags of Corruption must be reviewed and reported to CIC or your company’s Legal Department. Since they can be varied, spotting indicators of Corruption requires you to carefully review and understand the details of work you oversee.  Some examples of red flags of Corruption include:

• Undisclosed conflicts of interest;
• Unnecessary purchases or incomplete receipts;
• Unusual payment terms or accounts;
• Unexplained transaction(s) in a jurisdiction known for widespread Corruption;
• Invoices lacking detail or not relating to services listed in the contract;
• Poor record-keeping;
• Ongoing acceptance of poor service or quality;
• Lack of transparency in business dealings;
• Extravagant entertainment or gifts (for example, beyond what the Team Member would spend under applicable FedEx finance policies);
• Requests for secrecy or special treatment among suppliers or other Third Parties;
• Highly concentrated decision-making and centralized power of position;
• Agent, consultant, or other Third Party is suggested by a Government Official;
• Agent, consultant, or other Third Party is unwilling to comply with FedEx compliance requirements; or
• New Third Parties introduced late during negotiations.

 

For additional examples of red flags related to the use of Third Parties, review the Third-Party Anti-Corruption Compliance Manual.

 

FedEx Third Parties

The actions of the Third Parties with whom we do business may expose FedEx to significant liability under anti-corruption laws as well as potential business and reputational risk. Enforcement authorities consistently note that much of the corruption risk faced by organizations arises through the actions of Third Parties acting on their behalf. Therefore, we must take great care in selecting Third Parties and require them to act ethically and comply with all applicable laws, including all anti-corruption laws. 

 

As part of the third-party selection process and depending on the risk presented, CIC and/or the Legal Department may deem it necessary to conduct anti-corruption due diligence before FedEx engages the Third Party. The scope of due diligence is tailored to the level of risk presented by the Third Party. If you are uncertain whether a Third Party requires anti-corruption due diligence, or the degree of due diligence required, contact CIC or your Legal Department. 

 

Travel, Meals, Lodging, Gifts & Entertainment Reminders for Non‐U.S. Government Officials:

Team members must exercise care, know the applicable policies, and obtain any required approvals before offering or providing travel, meals, lodging, gifts, or entertainment to a Government Official or private person. These actions and activities, if done at the wrong time, too often, or in excessive amounts, could be considered a Bribe or Improper Payment.  Remember to also review the Global Gifts and Entertainment Policy when offering or receiving gifts to or from Third Parties. 

Knowing the rules and getting advice and approvals in advance will help you understand not only what is prohibited but also what may be appropriate and allowed in each situation.

 

U.S. Government Officials

Before offering or providing any travel, meals, lodging, gifts, or entertainment to U.S. Government Officials, Team Members must obtain advance, written approval from a member of the FedEx Corporation Government Affairs Department. Team Members must comply with any additional requirements indicated by the Government Affairs Department. If you need additional information, reach out to CIC at integrity@fedex.com.

 

Non-U.S. Government Officials

In some countries and territories, providing meals, gifts, travel, and/or entertainment to Government Officials is not allowed or restricted. Despite these restrictions, there are instances where we may be able to provide these items in moderation while remaining in compliance with law and our policies. You must properly record these expenses in the appropriate general ledger (see account ledger table below). If you have questions, please reach out to CIC or your company’s Legal Department.

 

Business Meal Expense Limits

A Team Member may pay for the cost of a business meal for a Government Official, if doing so (1) complies with local law and (2) the cost for each individual Government Official(s) does not exceed the total daily meal limit that would be permitted for a FedEx Team Member under the Business Travel, Entertainment and Other Expense Policy. 

• When there is a domestic meal limit in a particular country or territory and all attendees are based there, the domestic meal limit applies. The International meal limits apply when there are attendees from outside the country or territory where the meal is taking place, and also when there is not a domestic meal limit.
• If expenses are incurred on a recurring basis for the same Government Official(s) (e.g. several times per year, monthly, etc.), CIC and your regional legal compliance team must be notified and approve the expenses in advance. 

 

Travel and Benefits to Government Officals in Conjunction with Meetings

Travel, meals, lodging and entertainment must be reasonable and appropriate to the circumstances, not be lavish or create the appearance of impropriety or otherwise violate any law of the jurisdiction of the Government Official.

Travel, meals, lodging, or entertainment expenses may not include spouses, family members, or other guests of a Government Official not acting in an official capacity without prior written approval from CIC.

Any benefits provided in connection with meetings should be proportionate and related to the business purpose of the meetings. For example, providing four days of lodging for one day of meetings would be unacceptable. Also, any entertainment must be modest, business appropriate, non-extravagant, and within the same metropolitan area as the business meeting.

 

Gifts

No cash, gift cards, vouchers, or cash equivalent may be provided to a Government Official. Gifts or FedEx-branded Promotional Items must be:

• Given directly to the government agency, rather than to a Government Official
• Given openly and in accordance with local law;
• Customary in type and value;
• Given at an appropriate time or season (e.g. at a retirement party or to commemorate a holiday);
• Given as an expression of hospitality, esteem, appreciation, gratitude, or goodwill; and
• Not given to influence the recipient or someone else to help FedEx secure an improper advantage or obtain or retain business.

 

Documentation Required for Travel, Meals, Lodging, Gifts, or Entertainment Expenses of Government Officials

Team Members must include the following documentation for approval and reimbursement of travel, meals, lodging, entertainment, gifts, Promotional Items, and hospitality of Government Officials:

• Nature of the expense and extent of any associated costs;
• Date(s) the expense was incurred;
• Place(s) where the expense was incurred;
• Name(s) and title(s) of all recipients and persons present;
• Business purpose of the expense;
• Confirmation (for Promotional Items and gifts) that the Promotional Item or gift was given as an expression of hospitality, esteem, appreciation, or goodwill; and
• Confirmation of whether the Non-U.S. Government Official Gift Documentation Form or alternative process must be followed, and if so, provision of such documentation.

Any manager who reviews a request for approval and reimbursement of travel, meals, lodging, entertainment, gifts, Promotional Items, and hospitality of Government Officials must ensure the above documentation is sufficient, considering this and related policies and local law, before granting approval.  If there is any doubt about whether the documentation is sufficient, the manager should consult with the finance department, Legal Department or CIC.

The Team Member providing the expense to the Government Official is responsible for adhering to the requirements in this Policy. The manager of the Team Member in approving such expenses is also responsible for ensuring accurate recording. In certain countries and territories, Finance is responsible for reviewing the information within its region, country, or territory to ensure items are recorded in the correct general ledger account and maintain the correct supporting documentation and approval for the expense. For TNT entities, a copy of this documentation must be sent to the (senior) manager Financial Controller within 30 days of when the expense is incurred and must be recorded in the appropriate account number. The required supporting documentation must be uploaded into FedEx Cloud Financials (FCF) or an alternative accounting system with the journal entry. 

 

Ledger Account Numbers for Certain Expenses

                                      

Type of Expense	Account Ledger (FEC, FXL)	Account Ledger (TNT legacy where still exists)
Travel Other Expenses Involving Government Officials	712115	763500
Business Meals and Entertainment Involving Government Officials	712315	763500
Promotional Items/Gifts to Government Officials	791610	763500
Facilitation Payments	791600	763400

 

Charitable Contributions

Corrupt individuals and enterprises may use charitable organizations as a front to funnel money to themselves. These individuals may seek a donation in exchange for a favorable decision benefiting the donor. For this reason, charitable contributions are a potential source of Bribery risk. Never provide a charitable contribution to obtain or retain business or gain any other advantage or favorable treatment. When considering any charitable donations, remember the following: 

• Verify the charity is legitimate and the donation is for proper charitable purposes; 
• Review the facts, intent, timing, parties, and any relationship to ongoing discussions or deals to ensure there are no concerns of Bribery or Corruption; 
• Disclose to the Legal Department any business dealings FedEx has with any Third Party that encouraged FedEx to make a charitable contribution; 
• Confirm that the donation will not violate the law and complies with your company’s applicable contributions policy; and
• If a Government Official is involved, review the background and reputation of the intended recipient and get prior written approval from the Legal Department.

FedEx subsidiaries or international regions or specific jurisdictions may have additional, more restrictive policies that relate to charitable contributions (such as who may offer them or the criteria to be followed). Team Members must comply with all relevant laws, regulations, policies and approvals before making a charitable contribution on behalf of FedEx. 

 

Political Contributions

Corrupt individuals may offer to make favorable decisions in exchange for contributions to certain political campaigns where they can access the funds for their personal use, particularly in regions with high Corruption risk. 

Team Members are prohibited from making or authorizing a political contribution to a Government Official or political party, whether in cash or in kind, by or on behalf of FedEx. Please refer to the Code of Conduct and Policy on Political Contributions for more information. Contact the Legal Department with any questions. 

 

Extortion or Duress

Corrupt individuals may use fear, intimidation, or violence to get what they want. They may try to force others to improperly pay or Bribe them or coerce their victims to follow orders. If someone threatens your health or safety, you should take whatever action you deem appropriate to avoid imminent and potentially serious harm to you. Severe economic or financial consequences alone do not qualify as imminent and serious harm.

If you or someone acting on your behalf makes a payment due to extortion or duress, you must notify CIC at integrity@fedex.com as soon as possible. Provide as much information as possible, including the date, time, place, names of parties involved (if known), and a narrative of what happened. CIC will assist in determining how to code the payment expense if a payment was made.

 

Accounting Requirements

At FedEx, we require our Team Members to maintain accurate financial records and appropriate internal controls to prevent violations of law. These internal controls also help ensure that Management authorizes only proper business transactions. 

 

Team Members must keep appropriate books, records, and accounts that accurately and fairly reflect, in reasonable detail, all FedEx transactions and disposition of assets. Accuracy and details matter. Team Members must not create or falsify fictitious FedEx accounting or business records for any purpose. For example: 

• Do not create or maintain any unrecorded funds or assets of FedEx. 

• Do not make or participate in making any false or mislabeled entries in the books and records of FedEx. 

• Do not approve or make any payment on behalf of FedEx if any part of the payment is to be used for an improper purpose or if the purpose is misstated. 

• Do not directly or indirectly use any funds or assets of FedEx for any unlawful purpose. 

FedEx policy requires that all payments and expenses involving Government Officials be appropriately documented. There are no exceptions. Merely failing to document a payment or expense involving a Government Official may subject FedEx to substantial liability.

 

Training and Awareness

Anti-corruption education and awareness are crucial for Team Members’ understanding of Policy requirements. Managers must ensure that Team Members timely complete assigned anti-corruption education and awareness on a regular basis. The frequency and type of education depends on each Team Member’s job and risk. Please see CIC’s Training SharePoint site for more information. 

Certain FedEx Third Parties must also receive anti-corruption training to help them better understand the risk of Corruption. Please refer to the Third-Party Anti-Corruption Compliance Manual for detailed information regarding anti-corruption education for Third Parties. 

 

Auditing

The Internal Audit Department, in collaboration with CIC, regularly assesses compliance with this Policy and suggests enhancements as needed. The Internal Audit Department will also consider anti-corruption concerns as part of its regular audits of FedEx operations and books and records. 

 

Questions and Answers

Q1. A Government Official who is responsible for choosing a new logistics supplier asked us to hire a local consultant who “knows how things work.” It seems like the consultant could help us win business. Is this okay? 

A1. You should be concerned. This is a potential red flag or warning sign of Corruption. It is possible the consultant and Government Official have an arrangement to pass part of the consulting fees to the Government Official as a Bribe to award the business. Report the request to CIC, your company’s Legal Department, or the FedEx Alert Line and wait for guidance before proceeding. 

 

Q2. Can I pay a Facilitation Payment if it is common in my local area? 

A2. No. Facilitation Payments are illegal in most countries and territories and are prohibited by FedEx. Please report any request for a Facilitation Payment to the Legal Department.

 

Q3. How do I know if I am interacting with a Government Official? 

A3. Any person that works on behalf of a government agency or government-owned entity may be a Government Official under anti-corruption laws. Please contact the Legal Department for assistance in identifying Government Officials. 

 

Q4. My manager seems to prefer to do business with certain Third Parties. I think my manager may be getting benefits like cash and paid vacations. What should I do? 

A4. This may be an example of commercial Bribery and Kickbacks. You must report it to CIC, your company’s Legal Department, or the FedEx Alert Line. 

 

Q5. A Team Member is reviewing an invoice submitted by a Third Party. Several charges are described as “consulting fees,” but they do not correspond to any services listed in the applicable  contract. What should the Team Member do?

A5. Unclear or unexplained charges, such as vague “consulting fees,” are red flags that may indicate improper payments by a Third Party. The Team Member should not approve the invoice and should immediately notify their manager or their company’s Legal Department so the issue can be reviewed. FedEx must ensure that all payments to Third Parties accurately reflect legitimate services performed under the applicable contract. The company may be held responsible for improper payments or misconduct carried out on its behalf by a Third Party.

 

Q6. A customs official asks a Team Member to route prohibited items to them because they receive a commission when certain prohibited items are recovered. There are a number of customs officials that work in this facility, but the Team Member knows if they agree to this request, this particular official will then ‘owe us a favor’ when we need it. The Team Member is not getting any personal benefit, so is it okay to agree to this request?

A6. No, the Team Member must refuse this request and explain that it violates our Policy. The Team Member would be subject to discipline, up to and including termination. Just because the Team Member does not personally benefit from this arrangement does not mean FedEx would not benefit from the Team Member helping enrich one customs official.  The Team Member must also report this occurrence to CIC, your company’s Legal Department or the FedEx Alert Line.

 

Q7. A large FedEx customer is currently negotiating a contract with FedEx. The customer asks a Sales Manager if their child can intern with FedEx this summer. Is this allowed?

A7. No. This request is not permitted under our Policy. Offering or providing an internship (paid or unpaid) to the child of a current or prospective customer during an active contract negotiation can be viewed as an improper advantage or Bribe. The Sales Manager must decline the request immediately and notify the Legal Department or CIC.

 

Review Period

This Policy undergoes an annual review. It is also reviewed on an ad hoc basis due to changes in law or our risk profile.

 

Acknowledgement

As part of onboarding, training or remediation, Team Members may be required to periodically acknowledge that they have read, understand, and will comply with this 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 education, communication, enforcement and compliance with this Policy. Anyone who does not comply with this Policy shall be subject to disciplinary action, up to and including termination.Responding to a Request for a Bribe.

 

Reporting and Anti-Retaliation

If you know or suspect there is a violation of this Policy, speak up and report it to your manager, human resources, your company’s Legal Department, or the FedEx Alert Line.

Go to fedexalertline.com to report online or find the phone number that applies to your country or territory. In the U.S., the phone number is 1.866.42.FedEx (1.866.423.3339). 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 and Procedures

Code of Conduct 
Third-Party Anti-Corruption Compliance Manual
Global Gifts & Entertainment Policy 
FedEx Finance Policy Manual: Business Travel, Entertainment and Other Expense Policy
FedEx Logistics Global Finance Policies
Policy on Political Contributions 

 

Approvals

Department: Corporate Integrity and Compliance
Policy Custodian: Chief Compliance Officer
Policy Adopted Effective: 18 August 2026