FedEx Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	FedEx Corp has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has clearly named numerous specific climate policies it has engaged with, such as the "EPA's Proposed GHG Standards for Heavy Duty Vehicles Phase 3," "Growing Climate Solutions Act of 2021," "Sustainable Aviation Fuel (SAF) Blenders Credit," "SEC Proposed Rule: The Enhancement and Standardization of Climate-Related Disclosures for Investors," "EU ETS," "UK ETS," "CORSIA," "Alternative Fuel Infrastructure Regulation," and many others. These disclosures include detailed information about the focus, category, and geographical scope of each policy, demonstrating a high level of specificity and transparency. FedEx has also provided detailed accounts of its lobbying mechanisms and targets. It mentions direct engagement with members of Congress and their staff, EU institutions, national governments, and U.S. federal agencies such as the EPA and FAA. The company also highlights its participation in trade associations like Airlines for America and the American Trucking Associations, as well as its submission of comment letters to the SEC. These disclosures provide clarity on both the direct and indirect methods of engagement and the specific policymaking entities targeted. Furthermore, FedEx has been transparent about the specific policy outcomes it seeks. It has outlined measurable goals, such as advocating for incentives to increase the production of sustainable aviation fuels (SAFs), supporting the SAF Grand Challenge to develop regional SAF supply chains, and promoting the adoption of international standards like CORSIA. The company has also disclosed its support for expanding EV infrastructure, modernizing European airspace to reduce emissions, and incentivizing the greening of transport modes. These detailed and measurable outcomes reflect a clear articulation of the desired policy changes and the rationale behind them. Overall, FedEx's disclosures illustrate a comprehensive approach to climate lobbying transparency.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	FedEx demonstrates a strong governance process for climate lobbying alignment, with clear oversight structures and monitoring mechanisms. The company explicitly mentions aligning its indirect lobbying efforts, including direct lobbying activities and lobbying conducted through trade associations, stating that "FedEx works with various government and industry organizations to lobby for various proposals and initiatives that address climate challenges, particularly as it relates to FedEx and the transportation ecosystem." Additionally, FedEx has described a policy to ensure alignment of climate lobbying activities, noting that "management is responsible for monitoring the appropriateness and effectiveness of the political activities undertaken by the most significant trade associations of which FedEx is a member." The company also identifies responsible parties for overseeing climate lobbying alignment, such as the "Corporate Vice President for Government and Regulatory Affairs, who reports directly to the FedEx Executive Vice President, General Counsel and Secretary," and the "Governance, Safety, and Public Policy Committee (the 'GSPP Committee') of the FedEx Board of Directors," which assists in oversight of political activities and expenditures. Furthermore, FedEx engages in periodic reviews and discussions with senior leadership to ensure alignment, stating that "on an annual basis, the Government and Regulatory Affairs Department engages with the company's senior business leaders to review long-term strategic priorities, identify associated public policy risks and opportunities, and develop prioritized action plans." This indicates a robust governance framework for climate lobbying alignment, encompassing both direct and indirect activities, with clear accountability measures in place.	3