Uphold Highest Ethics
Public Policy
ConocoPhillips’ code of business ethics and conduct regulates our interactions with public officials. Our public policy committee of the board of directors approved policies and guidelines, available on our Web site (http://www.conocophillips.com/sd/politicalpolicy), for employees to ensure corporate compliance with politically related laws and regulations. U.S. federal laws strictly forbid the use of corporate funds for candidates campaigning for federal office, but do allow companies to establish an employee political action committee (PAC) and fund the cost of administration. Contributions from Spirit PAC, our U.S. employee PAC, are guided by the following criteria: the candidate’s integrity and character; leadership potential; positions on issues and voting record; relevance to company operations; nature and strength of the candidate’s election opposition; and the candidate’s access to other sources of financial assistance. Contributions go directly to the candidate, generally avoiding independent expenditures in support or opposition of a candidate; out-of-election cycle contributions; contributions to presidential campaigns, leadership PACs or national political parties; and large contributions to trade association PACs. All corporate political contributions to candidates are approved by the executive vice president with responsibility for government affairs or his or her designee, reviewed by either internal or outside counsel prior to being issued and are reported quarterly to the public policy committee of the board of directors. All Spirit PAC political contributions are reviewed by a 10-member board of employee volunteers representing a cross section of the business units within the company. The Spirit PAC treasurer or assistant treasurer reports all receipts and disbursements to the Federal Election Commission and appropriate state agencies. An audit of corporate political contributions and of Spirit PAC receipts and disbursements is conducted each year. In addition, the articles of organization of Spirit PAC require that all employee contributors receive a complete listing of the contributions made by the PAC by March 31 of each year. All political contributions are reported twice a year to the compliance and ethics committee. Further details of these contributions can be found on our Web site (http://www.conocophillips.com/sd/politicalpolicy). In 2006, corporate contributions to state and local candidates in the United States and Canada (the only countries in which ConocoPhillips makes political contributions) totaled $291,970. Spirit PAC contributions totaled $478,500. ConocoPhillips also makes corporate political contributions in states where it is allowed to address issues significantly impacting our operations. These contributions totaled $5.6 million during 2006. ConocoPhillips also has a number of employee lobbyists and retained lobbyists. These individuals represent the company at the state and federal government level in the United States. These employees and retained lobbyists file the necessary lobbying disclosure forms with the appropriate state and federal agencies.