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 was established to ensure adherence with applicable laws and the highest ethical standards, promote a positive corporate reputation, prevent criminal and civil liability, and set 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 program.

Code of Business Ethics and Conduct

Our ?Code of Business Ethics and Conduct explains our standards as well as our legal and ethical responsibilities and provides concrete guidance for expected behaviors. It covers a range of topics including business ethics, anti-trust, anti-corruption, gifts and entertainment, and political involvement.

New employees receive training on the Code of Business Ethics and Conduct and all employees receive web-based training periodically. All employees are also required to read the code annually and confirm compliance. Employees who are most exposed to legal risks, like corruption, take part in web-based training and other targeted training. In addition to corruption training, we also teach employees how to deal with situations that may involve laws or regulations regarding political activities, antitrust, economic sanctions or export controls.

Systems and Practices for Reporting Violations

We encourage employees and contractors to ask questions and seek guidance about ethical concerns and we give them tools to guide ethical decision-making so they can understand their responsibility to report actual or suspected misconduct. We have several confidential reporting mechanisms including speaking to a trusted manager, supervisor, human resource representative or a 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 anonymously through our 24-hour ?Ethics Helpline. The Ethics 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 2018, we received guidance requests from employees and stakeholders across our businesses, investigated concerns, and took appropriate action when necessary. Depending on the scale and type of concern, issues are elevated to provide appropriate management-level oversight. Additionally, senior management and the board are provided regular updates on our ethics and compliance program activities, so they can ensure that the program appropriately addresses the compliance and ethics risks in our business and is working effectively.