FedEx Code Of Conduct

Transcription

FedExCode ofConductOur Guide to Deliveringthe Purple Promise

FedExCode ofConductOur Guide to Deliveringthe Purple PromiseIntroduction 2Earning the Trust ofOur Team Members 5Earning the Trust ofOur Customers 15Earning the Trust ofOur Communities 21Speaking Up 27Conclusion 31Letter from theChairman 3Responsibilitiesof FedEx TeamMembers 6Gifts, Travel andEntertainment 16Environment andSustainability 22Open-Door Policy 28Enforcement 32Data Securityand Privacy 17Corruption, ImproperPayments andBribes 23FedEx Alert Line 28Waivers 32Reports RegardingFraud, Accountingand InternalControls 29ConcludingAdvice 33What ConnectsUs MakesUs Stronger 4Every ActionMatters 4Responsibilities ofFedEx Managers 7Health and Safety 8Antitrust andCompetition 18Workplace Security 9Insider Trading 19Equal Opportunity andAnti-Harassment 10Human Rights 11Conflicts of Interest 11CorporateOpportunities 12Theft, Damageor Loss 13IntellectualProperty 13ConfidentialInformation 14AccurateRecordkeeping 14Fraud, Accountingand InternalControls 19PublicDisclosures 20InternationalTrade Controls 25Money LaunderingPrevention 26Political Activitiesand Contributions 26Investigations 30Non-Retaliation 30

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersEarning the Trust ofOur CommunitiesSpeaking UpConclusionLetter from the ChairmanTrust and reliability are critically important to our customers. FedEx teammembers earn this trust each day by delivering the Purple Promise — to makeevery FedEx experience outstanding.What guides team members toward trustworthy behaviors is the FedEx Codeof Conduct. It shows us how to act lawfully and ethically at all times, even ifit costs us business or profits in the short term.Please read this Code to develop a working knowledge of the laws and ethicalstandards that directly affect your job. In addition, since the Code cannot coverevery situation, it’s important that you read other FedEx policies, manualsand handbooks as well. Above all, don’t hesitate to ask your manager, humanresources, or a FedEx attorney to advise you before making a decision.If you believe that a legal or ethical violation has occurred, report it to yourmanager, human resources, security or legal departments, or the FedExAlert Line. Our Code and policies forbid any form of retaliation against you forreporting concerns in good faith.Our officers, directors and managers have the additional responsibility ofpromoting the principles set forth in the Code and fostering a culture in whichethical conduct is recognized, valued and demonstrated by all team members.Our commitment to doing the right thing depends on our leaders’ ability to setthe proper tone and address suspected violations promptly, with careand respect.Thank you for taking the time to read and comply with this Code, and for yourcontinued dedication to maintaining our outstanding reputation for trust andreliability. Remember, when it comes to integrity, every action matters.Sincerely,Frederick W. SmithChairman and CEOFEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 3

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersEarning the Trust ofOur CommunitiesSpeaking UpConclusionWhat Connects UsMakes Us StrongerThe FedEx Code of Conduct connects all FedEx team members, no matterwhere we are around the globe. The Code sets out principles of ethics andbusiness conduct that enable each of us to deliver the Purple Promise forour customers, communities and each other.The Code applies to every officer, director, manager and employee (collectively“team members”) of FedEx Corporation and its subsidiary companies.Certain sections of this Code alsoEXAMPLES OF THIRD PARTIES:apply to third parties performing Express Global Service Participantsservices on behalf of FedEx. You Ground Service Providersshould read the Code, together PUD Subcontractorswith any other FedEx policy, manual, Linehaul Subcontractorshandbook or contract that applies Cartage Agentsto your job, as ethical and business FedEx Authorized Ship Centersconduct questions arise.Every Action MattersAt FedEx we are committed to the Purple Promise: I will make everyFedEx experience outstanding. This commitment sets the bar forexcellence, helping us earn the trust and loyalty of our team members,customers and communities and making FedEx one of the mostadmired companies in the world and a great place to work.Complying with the law and acting ethically are essential parts ofdelivering the Purple Promise. Some types of laws affect everyone, suchas those concerning health and safety. Other laws primarily affect teammembers and third parties in particular roles, such as those concerningthe operation of our transportation networks, financial reporting orcustomer service. In the Code, we break down key laws and ethicalstandards into the principles of integrity and business conduct that apply to ouractions every day.If you have questions about the principles described in the Code, ask your manager,your operating company’s human resources, security or legal department, or theCorporate Integrity & Compliance Department at integrity@fedex.com.When it comes to integrity and business conduct — EVERY ACTION MATTERS!FEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 4

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersEarning the Trust ofOur CommunitiesSpeaking UpConclusionEarning theTrust of OurTeam MembersWe develop highly motivatedand effective team membersby fostering a safe workplacethat values diversity, inclusion,teamwork and respect foreach other and FedEx.FEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 5

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersEarning the Trust ofOur CommunitiesResponsibilities ofFedEx Team MembersyRespeINTEGRITYReConclusionQFedEx raises the bar forperformance each year,and we always seem to beunder pressure to achieve betterresults. Do my obligations tomeet business and financialgoals come before myobligations in this Code?cHonest Promptly reporting anyknown or suspectedviolations of law, theCode, or FedEx policiesand proceduresliable Asking questionsorthtwSpeaking UpOur Code in Actionltfu Reading and followingthe CodeTrusAs FedEx team members, we all must actwith integrity and maintain the trust of ourfellow team members, customers andcommunities. We’re responsible for:Fair ANo. Our interests arenever served by unlawfulor unethical business conduct.FedEx is one of the mosttrusted brands in the world.Maintaining the highest ethicaland professional standardsis critical to maintaining thisvaluable trust.FEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 6

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersEarning the Trust ofOur CommunitiesSpeaking UpConclusionResponsibilities ofFedEx ManagersFedEx managers have additional responsibilitiesunder the Code. Showing your commitment to ethicsand integrity in your everyday actions is the singlemost important factor in earning trust and fosteringa culture in which team members follow the Code.You’re responsible for: Reading and following the Code Reinforcing key messages in the Code Ensuring team members are comfortablespeaking up and asking questions Being available and listening when teammembers have questions or concerns Preventing retaliation against team memberswho report concerns in good faith Enforcing the Code and FedEx policies andprocedures promptly and consistentlyFEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 7

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersEarning the Trust ofOur CommunitiesHealth and SafetySpeaking UpConclusionOur Code in ActionWe are committed to maintaining a healthy and safe workplace. We must complywith the health and safety laws and policies that apply to our jobs and prevent unsafeworking conditions — no exceptions! This includes maintaining an alcohol-free anddrug-free workplace in accordance with FedEx policies and national, state and locallaws. Third parties who work with us must also follow all health and safety laws andFedEx policies and commit to keeping our workplaces free of alcohol and drugs.We’re all responsible for reporting unsafe working conditions.Report concerns about workplace health or safety to yourmanager, your safety specialist, your operating company’shuman resources or legal department, or the FedEx Alert Line.QI hurt my back at work,but I don’t want to report itbecause I was partly to blame andit will break my team’s injury-freerecord. What should I do?AYou must report all injuriesor accidents to your manager,a safety specialist, humanresources or your FedEx businesscontact as soon as possible soFedEx can take action and workto prevent similar incidents inthe future.FEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 8

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersEarning the Trust ofOur CommunitiesSpeaking UpConclusionWorkplace SecurityWe are committed to maintaining a safe and secureworkplace. We prohibit, and will not tolerate, violentor threatening behavior by or against FedEx teammembers, third parties or other individuals. Prohibitedactivities include intimidation, bullying, stalking, physicalassaults, and written, spoken or physical threats directedat a team member, third party or other individuals.We’re all responsible for reporting situations that havethe potential for workplace violence. Never assumethat a threat or suspicious activity indicating a potentialfor workplace violence is not serious. All threats orsuspicious activities must be reported. If it is an emergency and you’re in the U.S., dial911. Outside the U.S., call your local emergencyresponse number. If the threat or actions indicate a potential forviolence, but do not pose an immediate danger,report the situation to your manager, FedEx Securityor the FedEx Alert Line. Finally, in many locations team members mayuse LiveSafe to receive security notifications,connect to emergency response numbers andreport tips and information to FedEx Security.LiveSafe is available through the LiveSafe mobileapplication, the Workday Other Resourcesmobile application or designated Workplace Violencecomputer terminals at FedExPreventionfacilities.Our Code in ActionQOne of the team members on my shift is easilyagitated and has made comments that make meafraid for my safety. What should I do?AReport your concern to your manager, FedExSecurity, LiveSafe or the FedEx Alert Line. FedExtakes signs of potential workplace violence veryseriously and will act to ensure we continue to provide asafe work environment.FEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 9

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersEqual Opportunityand Anti-HarassmentOur greatest asset at FedEx is our people. We arecommitted to equal opportunity, fairness, respectand inclusion and do not tolerate discrimination orharassment based on race, color, ethnicity, nationalorigin, religion, sex, age, genetic information, citizenship,disability, marital status, pregnancy, sexual orientation,gender identity, gender expression, veteran status orany other characteristic protected under national, stateor local laws.We recruit, hire, contract, evaluate, compensateand promote based on job-related qualifications andperformance. We will reasonably accommodate teammembers and third parties with physical and mentaldisabilities unless such accommodation imposes anundue hardship on our business.We prohibit sexual harassment. Sexual harassment maytake many forms, including unwelcome sexual advances,requests for sexual favors, threats and unwanted physicalcontact. Sexual harassment may also occur throughwords or actions such as inappropriate comments orgestures, unwelcome email or text messages, or picturesor comments posted on social media.Earning the Trust ofOur CommunitiesSpeaking UpConclusionIT COULD BE HARASSMENTIf it looks like arytouchingOr sounds like thisXXX!?discussingsexual activity#@!%name callingHAHAcommenting onphysical attributesbadlanguage?crudejokesIf you witness or experience discrimination or harassment,report it to your manager, your operating company’s humanresources or legal department, or the FedEx Alert Line.Our Code in ActionQI heard my manager say that when a woman becomespregnant, it interferes with her job performance. I believeI did not receive a promotion because my manager knowsI am pregnant. Is there anything I can do?AYes. You should report the situation to your company’shuman resources or legal department. If you wish to remainanonymous, you can make a report through the FedEx Alert Line.FEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 10

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersEarning the Trust ofOur CommunitiesSpeaking UpHuman RightsConclusionPROHIBITEDACTIVITIES:We are committed to protecting and advancing human rights in all of our operationsaround the world. We prohibit the use of child, compulsory or Other Resourcesforced labor. We have zero tolerance for, and prohibit, slavery and Policy Prohibitinghuman trafficking. We pay fair wages and comply with wage lawsTrafficking inin all the countries where we operate. We require our third partiesPersonsand suppliers to uphold these important principles.Conflicts of InterestFedEx respects team members’ rights to manage outside activities and financialinterests. At the same time, while employed by FedEx, your primary business loyaltymust be to FedEx. If personal interests create, or appear to create, conflicts of interest atwork, it may affect your ability to act honestly and in the best interests of FedEx whenmaking business decisions.To avoid conflicts of interest, we must avoid activities, investments or close personalrelationships that create, or appear to create, a conflict between our personal interestsand the interests of FedEx. Close personal relationships include people who are familymembers, living together, dating or engaging in an intimate relationship. In addition,FedEx specifically prohibits team members or close personal relationships from acceptingmoney, gifts or personal benefits in return for awarding FedEx business. Forced labor Confiscation of identityor immigrationdocuments Use of recruiters whoviolate local labor laws Misleading claims aboutwages, benefits, locationof work, housing and jobhazardsSITUATIONS THATCOULD LEAD TO ACONFLICT OF INTEREST: Work outside FedEx Hiring or managingclose personalrelationships Board memberships Ownership or financialinterests Being paid by a vendor orsupplier to write an articleor speak at an eventIf you become aware of an actual, potential or apparent conflict of interest, you mustdisclose the conflict to your manager in writing. Your manager will assess the situationand work with human resources or legal, as appropriate, for review, guidance or action. Other Resources Global Gifts &EntertainmentPolicyUnless preapproved by the Executive Vice President and ChiefFinancial Officer of FedEx Corporation, you may not hire any personwho has been employed during the preceding three years byFedEx’s independent auditor (currently, Ernst & Young LLP).Our Code in ActionQI was recently promoted to manager. My girlfriendalso works at FedEx and now reports to me.We both want to keep our jobs at FedEx. What shouldwe do?AManaging your girlfriend creates a conflict ofinterest. You should disclose your relationship inwriting to your manager. Your manager will review thesituation and involve human resources or legal to addressthe conflict.FEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 11

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersEarning the Trust ofOur CommunitiesSpeaking UpConclusionOur Code in ActionCorporate OpportunitiesWe are committed to protecting FedEx business opportunities. Third parties,suppliers, customers and others routinely present ideas and opportunities toFedEx. In addition, we may discover or develop ideas for new FedEx business,technology or investments. These ideas and opportunities are the exclusiveproperty of FedEx. Team members may not take FedEx technology, ideas oropportunities for personal benefit or compete with FedEx without the priorwritten consent of your operating company’s legal department.Officers and directors have additional responsibilities to protect FedExbusiness opportunities and should contact FedEx Corporation’s GeneralCounsel for questions or guidance.QI recently spoke to asupplier who told meabout a technology companythat FedEx may have an interestin buying. May I invest myown money in the technologycompany?ABefore investing, you shoulddisclose all of the details toyour operating company’s legaldepartment and wait to receivewritten consent to proceed.FEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 12

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersTheft, Damage or LossAs part of our Purple Promise we are committed toprotecting FedEx and customer resources and reportingpotential theft, damage or loss. Do not steal or mistreatFedEx or customer resources. Theft, damage and losshave a direct impact on our efficiency and ability to deliverthe Purple Promise.FedEx provides facilities, equipment, transportation andtechnology for use when carrying out our duties andresponsibilities for FedEx. Always exercise good judgmentwhen using FedEx resources. Technology resources suchas laptops, power pads, tablets and smartphones areprovided to help do your work for FedEx. Minimal personaluse of FedEx technology resources may be acceptableif it’s allowed by your FedEx operating company anddoes not interfere with your job duties. However, almostany form of communication using FedEx resourcesmay be a company record. Unless prohibited by law,FedEx reserves the right to retrieve and review yourFedEx laptop, power pad, tablet, smartphone and anyinformation stored on FedEx servers, including emails,text messages and internet browsing history, with orwithout your knowledge or consent.If you witness or become aware of potential theft,damage or loss our Purple Promise encourages you toreport it to your manager, your operating company’shuman resources or security department, LiveSafe orthe FedEx Alert Line. We will promptly respond to yourEarning the Trust ofOur CommunitiesSpeaking UpConclusionreport and may, at management’s discretion, reward teammembers and third parties who provide information thatleads to the discovery of theft, damage or loss.Intellectual PropertyWe are committed to respecting patents, copyrights,trademarks and other intellectual property, includingthose that belong to FedEx. We will not reproducecopyrighted material or use intellectual property unlesswe have a license or permission to do so. Likewise,we distribute software only in accordance with theterms of applicable license agreements. Any use ofopen source software must be preapproved by ourInformation Security department and your operatingcompany’s legal department.We are committed to defending FedEx patents,copyrights and trademarks around the world. The FedExname and trademark may only be used in accordancewith applicable licenses and brand guidelines.EXAMPLES OF ITEMS THAT SHOULD NOT BE COPIEDWITHOUT LICENSE OR PERMISSION: Copyrighted books, articles, music, videos or pictures Licensed software Licensed trademarksOur Code in ActionQI’m preparing a presentation for a customer and foundmusic and video clips on the internet. Can I includethese in my presentation?AIt depends. The music and videos may be copyrighted.Check with your operating company legal departmentor legalreview@fedex.com before using them in yourpresentation.FEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 13

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersEarning the Trust ofOur CommunitiesSpeaking eepingWe are committed to protecting FedEx confidentialinformation. Confidential information is any non-publicinformation about FedEx business, team members,customers and suppliers such as business plans, pricing,costs, internal financial information, personal data,research and development, FedEx-owned technology,marketing plans and any other competitive information.We are committed to maintaining records to meet ourfinancial, legal and operational requirements. Manyteam members and third parties are involved with FedExrecords such as time sheets, expense reports, hoursof-service logs or customer transactions. In addition,some team members and third parties are involved increating legal, financial or operational records. We mustall act honestly and ensure FedEx records are accurate,complete, reliable and secure. Intentional falsification orunauthorized destruction of any FedEx record — whetherpaper, electronic, scans, video, email, cloud storage, orany other format or location — is prohibited.Confidential information should not be misused ordisclosed during or after the term of your employmentor contract with FedEx. You may disclose confidentialinformation to other FedEx team members or third partiesonly if they have a legitimate, business-related need toknow the information.Exercise caution when discussing confidential informationin public places where conversations may be overheard,such as restaurants or elevators. Avoid readingdocuments with confidential information in public places,such as airplanes or trains, and do not discard themwhere others can retrieve them. Finally, where possibleand consistent with your operating company’s documentretention policy, you must securely dispose of documentscontaining confidential information.This section does not restrict communications by orbetween team members aboutwages, hours, or other terms and Other Resourcesconditions of employment. Also, Informationthis section does not prohibitSecurity Policy Social Mediayou from reporting information toGuidelinesany government agency or self Messagingregulatory organization or engagingApplicationin activities protected underGuidelineswhistleblower statutes.FedEx record retention requirements are based onspecific laws and business requirements. Regularly checkyour operating company’s record retention schedules toensure you are maintaining all required records. Neveralter or destroy a FedEx record if you have been notifiedby the legal department that it is the subject of a legalhold because of a pending or threatened legal claim.If there is no legal hold and the scheduled retentionperiod has expired, you should dispose of the recordin accordance with your operating company’s recordretention policy, procedures and schedules.Our Code in ActionQThere are a lot of new messaging platformsavailable now. Can I use a messaging app tosend a customer pricing information?ANo. FedEx prohibits disclosure of confidentialinformation on social media sites, messagingapplications, public blogs, or similar publicly availablesites and applications. FedEx has additional guidelinesfor the use of social media and messaging apps.FEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 14

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersEarning the Trust ofOur CommunitiesSpeaking UpConclusionEarning theTrust of OurCustomersWe listen to customersand strive for excellencethat enables us to meettheir needs and exceed theirexpectations while adheringto the highest ethical andprofessional standards.FEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 15

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersGifts, Travel andEntertainmentEarning the Trust ofOur CommunitiesBusiness gifts build relationships. But they can also look like bribesto outsiders, so we’re legally required to manage how we handleWhen giving or receiving gifts, meals, travel or entertainment,be sure to understand the limits placed by the FedEx GlobalGifts and Entertainment Policy. Business gifts, meals, travel andentertainment should be moderate, appropriate to the countryor culture, and intended only to promote business relationships.Gifts, meals, travel and entertainment that are repetitive (nomatter how small) may create an obligation to the giver and areprohibited. Gifts of cash or cash equivalents, such as gift cardsor gift certificates, are also prohibited.them. Here’s what’s usually OK to give or receive and what youneed to avoid.Usually OKpromo itemsThis policy applies at all times and doesnot change during traditional gift-givingseasons.Specific rules apply when offeringgifts, meals, travel or entertainmentto government officials. Refer tothe Governmental Contacts andLobbying Disclosure CompliancePolicy before offering anything toU.S. government officials and tothe Global Anti-Corruption Policybefore offering anything to nonU.S. government officials.flowersfoodCOMMON SENSE STILL APPLIES — If it’s expensive or you areunsure of the value, double check and get approval before givingor receiving — even if it’s one of these things.Never OKAs 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 Other Resourcesfavors from a third party, customer or Global Gifts &supplier. These actions may compromiseEntertainment Policy— or appear to compromise — your ability Governmentalto make fair business decisions.Contacts and Global AntiCorruption PolicyConclusionGIVE THIS, NOT THATWe are committed to promoting fair and transparent businessdecisions and protecting the reputation of FedEx. Reasonableand appropriate business gifts, meals, travel and entertainmenthelp promote relationships with third parties, customers andsuppliers. However, we should not give or receive anythingthat might improperly influence a business decision.Lobbying DisclosureCompliance PolicySpeaking Upcashgift cards andcash equivalentshigh-value giftsvacationsEVERYTHING ELSE — Check with your operating company’slegal department.Our Code in ActionQAA supplier invited me to a conference they sponsor and offered to pay for all my travelexpenses, including airfare, meals and accommodations. Can I accept?You may not accept the supplier’s offer to pay for travel and lodging for you or yourfamily members unless you receive prior approval from your operating company’sgeneral counsel. You may accept meals from the supplier as part of attending the conferenceas long as they are not lavish or excessive and comply with the guidelines listed in the Codeand Global Gifts & Entertainment Policy.FEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 16

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersEarning the Trust ofOur CommunitiesSpeaking UpConclusionData Securityand PrivacyWe are committed to maintaining the security and privacyof personal data provided to FedEx by team members,customers, third parties and others. Personal data isany information that can be used directly or indirectly toidentify an individual person, and includes a person’sname, phone number, address and email address, bothbusiness and personal.We will collect, record and use personal data in aproper and professional manner and are accountableto demonstrate compliance with the principles ofdata protection, including fair and lawful use, purposespecification, collection limitation, deletion, dataquality, security safeguards and transparency.All personal data provided to FedEx by team members,customers, third parties and others must be treatedas confidential. FedEx has implemented technical,administrative and physical procedures to protectpersonal data from unauthorized access, loss,misuse, alteration and disclosure.Any unauthorized access or Other Resourcesprocessing of personal data by Global PrivacyPolicyteam members or third parties FedEx Bindingis prohibited. If you discover orCorporate Rulessuspect a data security incident, Informationa cyberattack or a possible breachSecurity Policyof personal data, immediately Social MediaGuidelinesnotify your legal department or MessagingInformation Security using theApplicationIncident Notification Website,Guidelineskeyword “incident.”Our Code in ActionQI noticed that the name and address on a packageI was handling is someone who I want to contactabout a personal matter. Can I use the packageinformation to get in touch with her?AThe name and address of the shipper and recipientwere provided for use by FedEx as part of ourbusiness. Any use of the data beyond those businesspurposes, including contacting the individuals for personalreasons, is prohibited.FEDEX CODE OF CONDUCT OUR GUIDE TO DELIVERING THE PURPLE PROMISE 17

IntroductionEarning the Trust ofOur Team MembersEarning the Trust ofOur CustomersEarning the Trust ofOur CommunitiesAntitrust and CompetitionWe thrive in competitive markets and are committed to giving customers thebest value for our products and services. Antitrust and competition laws protectcustomers by promoting lower prices, more choice and greater innovation.Actions that violate antitrust and competition laws — such as agreements withour competitors to fix prices; divide customers, territories or markets; or notto recruit each other’s employees — are prohibited and simply not the waywe do business.The most serious antitrust violations arise from agreements amongcompetitors. Such agreements do not need to be written or even consist ofexpress commitments but can be inferred from informal agreements,

delivering the Purple Promise. Some types of laws affect everyone, such as those concerning health and safety. Other laws primarily affect team members and third parties in particular roles, such as those concerning the operation of our transportation networks, financial reporting or customer service. In the Code, we break down key laws and ethical