Global Anti-Corruption Policy

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Global Anti-Corruption Policy Global Anti-Corruption Policy Introduction dealings. Team Members must exercise FedEx is committed to doing business ethically appropriate oversight over their area of and in compliance with the law. An important responsibilities and maintain adequate internal part of that commitment – and our commitment financial controls and keep accurate books and to integrity – is our strong opposition to records so as not to allow Bribes or other Corruption and Bribery in any form. Improper Payments to occur and be disguised as legitimate business expenses. FedEx operates in more than 220 countries and territories around the world. Our global network Scope of operations offers both distinct opportunities This Policy applies to every officer, director, and risks. To help protect our company and manager and employee of FedEx Corporation and reputation, we must comply with the law, avoid its subsidiary companies (each, a “Team doing business with those who do not respect the Member”). law, and understand and address our risks Definitions wherever they exist. “Bribery” or “Bribe”: anything of value offered, Policy Overview given or received in exchange for a favorable FedEx prohibits Corruption and Improper decision or exercise of discretion by a Government Payments in all our business dealings throughout Official or private person. the world. Team Members must not directly or “Corruption”: dishonest or fraudulent conduct, indirectly, offer, authorize, request, give or including the misuse or abuse of power, influence receive anything of value to or from any person or or position; some common types include organization to obtain or retain business or kickbacks, Bribery, influence peddling and influence a decision or action. extortion. Team Members also must not participate in or “Facilitating Payment”: anything of value, allow Corruption to influence a business decision typically a small payment or gift, offered or or gain an undue business advantage. provided to a Government Official to facilitate or expedite routine clerical or administrative, non- Objectivity, fairness, transparency and diligence discretionary actions such as inspecting goods in are key to avoiding Corruption in our business 1 transit, issuing permits and/or licenses, processing “Management”: any Team Member of FedEx visas or providing police protection. managing at least one other employee. For purposes of the approval process under this Policy, “Government Official(s)”: any elected or Management refers to the immediate supervisor appointed officer, employee or other person of the person seeking approval or a more senior performing service on behalf of a government, member of Management with appropriate government agency, state-owned or -controlled decision-making authority. entity, military, political party, or public international organization. This definition includes Corruption, Improper Payments and Bribes both U.S. and non-U.S. Government Officials. FedEx and the Third Parties with whom we do “Improper Payments”: anything of value used to business enable trade by connecting people, corruptly influence the decision or action of a goods, businesses and markets around the world. Government Official, private person or business. Corruption risk appears in different forms and Includes Bribes, Facilitating Payments and levels throughout the world. Corruption can be kickbacks. tied to government or private activities and can “Third Party”: any prospective or current non- occur in a number of situations we may encounter FedEx entity, customer, vendor, supplier, service in our work, such as: at border crossings during provider or any other person with whom FedEx customs clearance; in business solicitation, does or may do business. negotiations, meetings or transactions; when interacting with Government Officials; or related “Promotional Item”: goods prominently featuring to entertainment, social, political or charitable the FedEx corporate brand or logo. These items matters. are generally available in the company store or catalog. FedEx Team Members must be able to recognize Corruption risk in their work and be alert to “Team Members”: every officer, director, situations where prohibited activity such as manager and employee of FedEx Corporation and requests for Bribes or other illegal activities may its subsidiary companies. occur. Upon recognizing the risk, Team Members must uphold our strong opposition to Corruption 2 and Bribery by refusing to approve or participate in corrupt schemes or deals and immediately Understanding Bribery reporting such prohibited activity to your company’s Legal Department as soon as you learn Anything of value offered, given or received in of it. exchange for a favorable decision or exercise of discretion by a Government Official or private Facilitating Payments person is a Bribe. Bribery and Improper Payments Anything of value, typically a small payment can be anything of value including: or gift, offered or provided to a Government Money Official to expedite routine clerical or Kickbacks administrative, non-discretionary actions Unposted fees such as inspecting goods in transit, issuing Unwarranted discounts permits and/or licenses, processing visas or Payments disguised as commissions providing police protection. Travel, meals, lodging, gifts and entertainment FedEx prohibits Facilitating Payments Favors because they violate the anti-corruption laws Charitable and political contributions of most countries, are often poorly Jobs and internships documented and tend to encourage and perpetuate Corruption. If you are asked to pay a Facilitating Payment, refuse and immediately contact your company’s Legal Department. Official fees, documented in writing, that are required by a government to perform certain legitimate services are not considered Facilitating Payments. 3 Travel, Meals, Lodging, Gifts & Entertainment Team Members must exercise care, know the Travel, Meals, Lodging, Gifts & rules and obtain any required approvals before Entertainment Reminders for Non-U.S. offering or providing travel, meals, lodging, gifts or Government Officials: entertainment to a Government Official or private Don’t give cash, gift cards or other cash person. These actions, if done incorrectly, at the equivalents. wrong time, too often or in excessive amounts, When allowed, Promotional Items are could be considered a Bribe or Improper Payment. preferred as gifts and you should first ask, Knowing the rules and getting advice and can you accept a ____ (noting type of approvals in advance will help you understand not item)? only what is prohibited but also what may be Don’t use your own money, petty cash, or appropriate and allowed in each situation. third-party funds to pay for something that FedEx wouldn’t allow you to submit Before offering or providing travel, meals, lodging, as a business expense. gifts or entertainment to U.S. Government Officials, Team Members must obtain advance, Travel, meals, lodging, gifts or written approval from the FedEx Corporation entertainment expenses must not be Government Affairs Department. extravagant and expenses and attendance of any non-FedEx guests, such as Remember to also review the Global Gifts & significant others, requires advance Entertainment Policy when offering or receiving approval from your Legal Department. gifts to or from Third Parties. 4 If a Government Official is involved, review the Charitable Contributions background and reputation of the intended recipient and get prior written approval of Corrupt individuals and enterprises can use your company’s Legal Department. charitable organizations as a front to funnel money to themselves in exchange for making a Your company may have other policies that relate to charitable contributions (such as who may offer favorable decision to benefit the donor. For this them or the criteria to be followed). Team reason, charitable contributions are considered a Members must comply with all relevant policies potential source of Bribery risk. Never provide a charitable contribution to obtain or retain before making a charitable contribution on behalf of FedEx. business or gain any other advantage or favorable treatment. When considering any charitable Political Contributions donations, remember the following: Corrupt individuals may offer to make favorable Verify the charity is legitimate and the decisions in exchange for contributions to certain donation is for proper charitable purposes; political campaigns where they can access the funds for their personal use, particularly in regions Review the facts, intent, timing, parties and with high Corruption risk. any relationship to ongoing discussions or deals to ensure there are no concerns of At FedEx, we prohibit Team Members from Corruption; making or authorizing a political contribution to a Government Official or political party, whether in Disclose to your company’s Legal Department cash or in kind, by or on behalf of FedEx. any business dealings FedEx has with any Third Party that has encouraged FedEx to make a Some examples of prohibited activities include: charitable contribution; Making a financial donation to a political party Confirm that the donation would not violate or campaign on behalf of FedEx. the law and complies with FedEx policies and Loaning Team Members to work for a political procedures; and party or campaign, including allowing Team 5 Members to use paid leave of absence or Every Team Member has a responsibility to help additional vacation time for such work. recognize,
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