Justin Ross, Staff Vice President, Chief Compliance Officer at FedEx Corporation in Memphis, Tennessee, USA
AT: You began your career as an attorney with a law firm. What kind of practice did you have?
JR: I began my legal career with a medium-sized law firm in Memphis, focusing on defense litigation and trial work. I handled tractor-trailer accidents, product liability, premises liability, and general commercial litigation.
AT: At FedEx you initially worked in legal with a focus on litigation. Then in 2015, you joined the compliance team. Can you tell us a bit about how compliance is structured at the company to support the business?
JR: At the corporate level, there is the Corporate Integrity & Compliance Department, also known as CIC, which includes 16 full-time employees responsible for overseeing our compliance programs across the entire enterprise. This team reports to me and is made up of attorneys and compliance specialists. Our main areas of responsibility include our code of conduct; our anti-corruption, antitrust, data privacy, export controls, gifts and entertainment, and conflicts of interest compliance programs; compliance risk assessments; the FedEx Alert Line; and internal investigations. We also have compliance teams employed by the other various FedEx business units, which we refer to as the FedEx operating companies and international regions. These teams are responsible for compliance matters in their respective operating company or region and have dotted-line relationships with my team at the corporate level. I report up through the general counsel and have direct access to the audit committee of our board of directors, to which we provide regular updates on our various compliance programs and risks.
AT: You started as staff director for the compliance team. Tell us a bit about the role and what is involved.
JR: As the staff director for integrity and compliance, I was responsible for our global anti-corruption, third-party, antitrust, and gifts and entertainment compliance programs and for training and communications in those areas. I was also responsible for internal investigations, the FedEx Alert Line, and compliance risk assessments. I reported directly to the chief compliance officer at the time.
AT: So, going into the compliance team as a new member, what were your impressions of the compliance function? Put another way, what did you think you knew about compliance then?
JR: We created a more formal, centralized compliance function at the corporate level in 2015, and I was one of the first employees hired into this new structure by my predecessor, our first chief compliance officer. So, when I started, we had the challenge of building this centralized compliance function from the ground up. I’d had some compliance experience working for one of the FedEx operating companies, but this was mainly with internal investigations, remedial actions, and compliance training. I quickly learned that compliance is much broader than that, not only with subject matters but also with the skill sets that are necessary to be successful. Compliance professionals need to be subject matter experts in the various compliance programs in which they are responsible and have the skills required to implement and maintain these programs, such as training, communications, policy writing and management, and investigative and project management skills.