Uphold Highest Ethics
Business Ethics
ConocoPhillips is committed to a work environment in which our business is conducted with integrity, in accordance with the highest ethical standards and free from all forms of unlawful conduct. Our code of business ethics and conduct summarizes the standards of ethical conduct and compliance with the law expected of directors, employees, contractors and other individuals who work on the company’s behalf. The code is available on our Web site (http://www.conocophillips.com/sd/ethics) and has been translated into multiple languages. It has been distributed to all current and newly hired employees. Employees are obligated to report suspected violations of company policies or the law to the company’s ethics office, which initiates a confidential investigation. Ethical concerns may be reported anonymously, either via a toll-free international telephone hotline or by e-mail. The company’s corporate compliance and ethics committee, composed of senior executives and attorneys, provides regular reports to the chief executive officer, as well as to the audit and finance committee of the board of directors. These reports cover the results of annual code certifications, the state of compliance activities and the handling of reports of violations. We are committed to follow through on any findings with measures that address the situation and uphold our standards. On an annual basis, employees are required to certify their personal compliance with the code. In addition, ethics reminders are sent to all employees periodically. To help employees familiarize themselves with the code, ConocoPhillips provides an online video, which reviews the code and reaffirms that employees are expected to comply with the law and conduct all business to the highest ethical standards, and courses on a wide range of compliance and ethical issues relative to the company and its operations. These courses provide background information on each issue, answer frequently asked questions and offer self-administered quizzes to test employees’ understanding of the information. In 2006, all employees worldwide were required to complete a business ethics and conduct awareness training module designed to increase awareness of how and when the code of business ethics and conduct applies to their actions. Supervisors or managers may recommend or require completion of additional courses, especially for employees whose work requires training for a particular compliance area, such as the U.S. Foreign Corrupt Practices Act (FCPA), insider trading, sanctions, export controls, or antitrust or antiboycott concerns.