Code of Ethics Fedex\'s Code of Business

Code of Ethics

FedEx's Code of Business Conduct and Ethics is available in pdf format at http://fdx.client.shareholder.com/common/download/download.cfm?companyid=FDX&fileid=138778&filekey=6b957b1f-ac83-4b37-835b-8b24e63b338f&filename=code.pdf

A system of inquiry is a series of questions that are used to determine the ethics of a situation. The system of inquiry covers a wide range of subjects including decision-making, problem solving and behavior in a business setting (Ganly, 2010). The first step will be determining the who. FedEx's system of inquiry should involve a panel from a number of different units, in particular mixing different locations as FedEx management is highly centralized. The inquiry should be undertaken when some evidence has been gathered to suggest that there has been some ethical issue. Such inquiries can be expensive, so there should be some hope of coming to a conclusion, and that hope arises only when there is some evidence with which to begin an investigation.

The inquiry should be protected and have the freedom to operate with relatively anonymity in the course of the investigation. This will allow the team of investigators to gain access to key individuals without necessarily having to announce their specific purpose. The system of inquiry at FedEx should also have specific timelines for investigations that can be used to assess the effectiveness of the program, and perhaps there could be policy that sets a statue of limitations on internal actions. The issue of why is perhaps the most important. All investigations undertaken by the investigation team should be focused on inquiries that will uncover instances where the company's Code of Business Conduct and Ethics has been violated. This code is the central ethical guidepost for the company, so it should be considered that any act that does not appear to violate the code should not be the focus on an inquiry.

3. The system of inquiry should be focused first on fact-finding. Facts can be found in financial statements, records of communication and through an interview process. Each of these steps will form a component of the system of inquiry. If there is no suspicion of financial malfeasance, then the audit process can be replaced by an operations audit or other applicable observational data-gathering method.

For the Ground Operations Division of Express, a number of different questions can be asked. The first guideline in the code is "lawful and ethical behavior." If there is any suspicion of a violation of the law, this must be the first line of questioning -- for example if a courier is suspected of being complicit in the use of the company's service to transport illegal goods. The nature of the act should be discussed first, followed by a review of the circumstances.

The second guideline is with respect to conflicts of interest. In this situation, the system of inquiry should begin by questioning what the actions of the employee were. Then, the employee should be asked if he or she is aware that there is a conflict of interest, or is aware of the company policy with respect to conflict of interest. The interview step follows the investigation step where the investigators will gather information using the data that is publicly (internally) available. Following the interview, interviews with other employees and possibly non-employee stakeholders will follow.

The third guideline is with respect to bribery or other "corporate opportunities." This will require an analysis of both the legal ramifications in the home country and in the U.S., along with an examination of normal business practice in the country in question. The people involved will also be questioned with respect to their actions.

4. An example would be if a business manager is asked to pay a bribe in order to secure a lucrative customer overseas. If this is suspected, then the system of inquiry will proceed as follows. The first step in this type of situation will be to conduct an audit of the financial records, including petty cash. Such an audit will help to uncover a financial paper trail that can provide some evidence of a bribe transaction. The expense accounts associated with the employee in question will come under scrutiny here, as well as department accounts. Essentially all bank accounts and transaction records will be searched by a qualified financial audit team.

The second step will be to investigate any records pertaining to the account. This will include emails and phone calls involving the company, and records of any meeting should such records exist. There should be some records to show that an arrangement has been made. If the first two steps do not turn up any evidence of wrongdoing, then the investigation may be shelved at this point. It will be difficult to take the issue further without any hard evidence.

The third step in the system of inquiry will be to interview the employee in question. The interview should focus on first gathering information. The next phase of the interview would present the evidence gathered to the employee. The third phase would return to the employee to answer the evidence. The fourth phase of the interview portion will be to outline the company's viewpoint regarding the ethics of the situation, and the legal ramifications.

The first phase will be conducted by a professional forsenic auditing team from the company's audit department. If the audit department itself has been implicated in the issue, then an external audit team should be utilized. The second phase will be conducted using the company's in-house ethical investigation team, as will the third phase. These investigators should have no connection to the individuals that are being investigated.