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Gifts, travel and entertainment
We are committed to promoting fair and transparent business decisions and protecting the reputation of FedEx. Reasonable and appropriate business gifts, meals, travel and entertainment help promote relationships with third parties, customers and suppliers. However, we should not give or receive anything that might improperly influence a business decision.
When giving or receiving gifts, meals, travel or entertainment, be sure to understand the limits placed by the FedEx Global Gifts and Entertainment Policy. Business gifts, meals, travel and entertainment should be moderate, appropriate to the country or culture, and intended only to promote business relationships. Gifts, meals, travel and entertainment that are repetitive (no matter how small) may create an obligation to the giver and are prohibited. Gifts of cash or cash equivalents, such as gift cards or gift certificates, are also prohibited.
As a FedEx team member, we may never ask for gifts, meals, travel or entertainment from a third party, customer or supplier. In addition, we may not accept loans or favors from a third party, customer or supplier. These actions may compromise — or appear to compromise — your ability to make fair business decisions.
This policy applies at all times and does not change during traditional gift-giving seasons.
Specific rules apply when offering gifts, meals, travel or entertainment to government officials. Refer to the governmental contacts and lobbying disclosure compliance policy before offering anything to U.S. government officials and to the Global Anti-Corruption Policy before offering anything to non-U.S. government officials.
Data security and privacy
We are committed to maintaining the security and privacy of personal data provided to FedEx by team members, customers, third parties and others. Personal data is any information that can be used directly or indirectly to identify an individual person, and includes a person’s name, phone number, address and email address, both business and personal.
We will collect, record and use personal data in a proper and professional manner and are accountable to demonstrate compliance with the principles of data protection, including fair and lawful use, purpose specification, collection limitation, deletion, data quality, security safeguards and transparency. All personal data provided to FedEx by team members, customers, third parties and others must be treated as confidential. FedEx has implemented technical, administrative and physical procedures to protect personal data from unauthorized access, loss, misuse, alteration and disclosure.
Any unauthorized access or processing of personal data by team members or third parties is prohibited. If you discover or suspect a data security incident, a cyberattack or a possible breach of personal data, immediately notify your legal department or Information Security using the Incident Notification Website, keyword “incident.”
Antitrust and competition
We thrive in competitive markets and are committed to giving customers the best value for our products and services. Antitrust and competition laws protect customers by promoting lower prices, more choice and greater innovation. Actions that violate antitrust and competition laws — such as agreements with our competitors to fix prices; divide customers, territories or markets; or not to recruit each other’s employees — are prohibited and simply not the way we do business.
The most serious antitrust violations arise from agreements among competitors. Such agreements do not need to be written or even consist of express commitments but can be inferred from informal agreements, loose talk or the mere exchange of commercial information.
We must avoid any discussions with FedEx
- Team member wages
- Payments to third parties
- Sales promotions
- Terms and conditions of sale
- Commercial strategies of growth plans
- Any other FedEx-owned or commercially sensitive information
Antitrust and competition laws apply all the time, including at trade association meetings, social gatherings and during other informal contacts. If a conversation with a competitor enters an inappropriate area, make sure to protect FedEx and yourself by ending the conversation at once and reporting the matter to your operating company’s legal department immediately.
We are committed to respecting the role of FedEx in the marketplace and will not use material non-public information for trading stock directly or indirectly or tipping others to trade. Material non-public information is any information about FedEx, or another company such as a FedEx third party or customer, that has not reached the general marketplace and is likely to be important to investors when deciding whether to buy or sell stock.
Using material non-public information to buy or sell stock or to tip others to do so is illegal. We must take care not to disclose material non-public information to relatives, colleagues or friends.
Officers, managing and staff directors, certain other individuals in sensitive positions and FedEx Corporation board members are prohibited from trading in FedEx stock during FedEx-imposed “quiet periods.”
Fraud, accounting and internal controls
We are committed to open, honest and fair dealing with each other and our customers, suppliers and competitors and should not take unfair advantage of anyone through fraud, manipulation, deception, concealment, misrepresentation or any other unfair dealing practice.
We are committed to eliminating waste, fraud and abuse from FedEx accounts and maintaining the accuracy of FedEx accounting records. We must comply with the FedEx system of accounting and internal controls to ensure that FedEx accounts are accurate and used only for legitimate business expenses or expense reimbursement. In addition, all FedEx financial transactions, big or small, should be properly documented. Unrecorded or “off-the-books” funds or assets are prohibited.
We must ensure that only authorized persons execute transactions on behalf of FedEx or have access to FedEx assets or systems. Providing false, misleading or incomplete information impairs our ability to make good decisions, undermines trust in FedEx and may be illegal. Consult internal audit or your operating company’s finance or legal department if you have questions regarding FedEx accounting or internal controls.
We are committed to providing full, fair, accurate and timely disclosures in our public communications and in the reports we file with government authorities, including the U.S. Securities and Exchange Commission (SEC). Our disclosures enable our stockholders to understand:
- Key business risks and opportunities
- Critical accounting policies
- Important judgments we make in preparing our financial statements
We strictly comply with both the spirit and the letter of the laws governing public disclosures and reporting to the SEC. Only certain FedEx team members are authorized to release information on behalf of FedEx as part of their regular duties. Therefore, you may not speak on behalf of FedEx to the SEC, investment analysts, the media or through social media unless it is explicitly authorized as part of your job duties. Any inquiries from the media or investment analysts must be directed to the FedEx Corporate Communications or Investor Relations department.
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