Business Ethics

Our reputation and integrity depend on each employee, officer, director and those working on our behalf assuming a personal responsibility for our business conduct. Led by our chief compliance officer, our Global Compliance and Ethics team ensures adherence with applicable laws and the highest ethical standards, promotes a positive corporate reputation, reduces criminal and civil liability, and sets the tone for an ethical work environment. The team includes local ambassadors embedded in business units and functions who help support and administer our Global Compliance and Ethics program.

As part of our commitment to continuous improvement, we updated our investigation model in 2021 to include enhancements to our investigative processes and expanded engagement with our business units and functions. We aimed to improve efficiency of the management process and to increase the agility of our investigative services.

Aspects of our compliance and ethics program relevant to financial reporting are annually reviewed by the company’s external auditor, and global compliance and ethics processes are periodically audited by our internal audit function and external compliance experts.

Code of Business Ethics and Conduct

Our Code of Business Ethics and Conduct is the foundation of our compliance and ethics program, explaining our responsibilities and providing guidance for behaviors. It covers a range of topics including business ethics, competition law, anti-corruption, gifts and entertainment, conflicts of interest and political involvement. In 2021, we reviewed our current code. Using data from risk assessments and cultural gap analysis, we updated and added topics to our code.

All new employees receive training on the Code as part of their new hire training curriculum. Current employees have access to web-based training on the Code at any time and are periodically required to repeat this training. Employees who are most exposed to legal risks, such as corruption, take part in web-based training and other targeted training. Employees may also receive training on competition law, anti-boycott, economic sanctions, export controls, insider trading and political activities. We annually require employees to certify they have read the Code, made all required disclosures and reported all potential concerns. With exceptions for certain types of leave, 100% of employees completed this certification in 2021.

Systems and Practices for Reporting Violations

We encourage employees and contractors to ask questions and seek guidance about compliance and ethics matters and we give them tools to guide ethical decision-making. Employees also understand they have a responsibility to report actual or suspected misconduct. We have several confidential reporting mechanisms. They may speak to a trusted manager, supervisor, human resources representative or Global Compliance and Ethics representative. Additionally, there is an anonymous option. Any stakeholder, whether employee, contractor, shareholder or the general public may report an actual or suspected violation of the Code anonymously through our 24-hour Ethics Helpline . The helpline is hosted by a third party to ensure anonymity and is available worldwide via the web or phone in multiple languages. ConocoPhillips prohibits retaliation of any kind against employees for raising an ethical or legal concern.

In 2021, Global Compliance and Ethics received questions, concerns and requests for advice from employees and stakeholders across our businesses. As part of our updated investigation model, we investigated workplace conduct, conflicts of interest, financial and business integrity matters, misuse of company assets and other allegations. Remedial and disciplinary actions were taken whenever appropriate. Depending on the scale and type of concern, issues were elevated to provide appropriate management oversight. Senior management and the Audit and Finance Committee of the Board were also provided regular updates on our program, so they could ensure that the program promotes ConocoPhillips’ SPIRIT Values , addresses the compliance and ethics risks in our business and works effectively.