Political Contributions Policy

Federal law strictly prohibits the direct contribution of corporate funds to candidates running for federal office or to their campaign committees.

ConocoPhillips is authorized under law to establish an employee political action committee (PAC) and fund its administrative costs. Consistent with approval of the Public Policy Committee, SPIRIT PAC was formed to facilitate contribution of employee funds to federal candidates, as well as state and local candidates. Information on SPIRIT PAC political contributions is provided as a 5-year rolling archive, inclusive of the current report. 

The SPIRIT PAC Board of Directors has established in its operating guidelines the following nonexclusive criteria for selecting candidates to support:

• Integrity and character of candidate including upholding processes and rights bestowed by the Constitution as an exercise of democracy.
• The candidate’s holding of a leadership or policy position in his party or on a standing legislative committee, or the likelihood of the candidate’s attaining such position in the future.
• The candidate’s position and/or voting record on issues affecting the relationship of business and government and on economic and social questions of importance.
• The candidate’s relationship with or representation of an operating facility or company operations.
• The nature and strength of the candidate’s opposition in primary or general elections.
• Other sources of financial assistance available to the candidate.

In addition, the SPIRIT PAC Board of Directors primarily concentrates on contributions that go directly to candidates for office, generally avoiding:

• Independent expenditures in support of or opposition to a candidate.
• Out-of-election-cycle contributions.
• Contributions to Presidential campaign.
• Contributions to leadership PACs.
• Contributions to political parties.
• Contributions to trade association PACs.

Individual state and local laws govern contributions to candidates running for election to state and local offices. The Public Policy Committee sets a bi-annual budget for, and has authorized a strict process for the justification, approval and reporting of any corporate political contributions made in the U.S. where legal.

The guidelines for determining whether a corporate political contribution should be made to a candidate are the same as the political action committee guidelines above, including those contributions to be avoided.

The responsibility to approve and administer contribution requests has been delegated to the corporate officer responsible for government affairs or his or her designee. Accordingly, the Vice President, Federal & State Government Affairs, and Legal must approve all requests for U.S. state and local contributions. Information on corporate political contributions is provided as a 5-year rolling archive, inclusive of the current report. 

The SPIRIT PAC Board of Directors may elect to make state and local contributions in states where corporate contributions are not allowed subject to applicable laws and PAC operating guidelines.

Many industry and special interest groups, including trade associations, have created their own political action committees to help elect candidates to office. Corporate contributions to these external PACs are strictly prohibited under ConocoPhillips policy if the contributions are intended to be used to fund candidates or their election campaigns. This includes the expensing of any costs for events such as golf and fishing tournaments, hunts, dinners, silent auctions and other types of activities used by these PACs to raise funds. Corporate contributions to fund administrative costs of certain external PACs may be permitted if allowed under applicable law, if doing so advances company goals, and if approved by Government Affairs and Legal.

For ConocoPhillips purposes, independent expenditures are defined as those funds given or expended to directly support or defeat a candidate, without collaboration of the candidate.

Our policy is not to make independent expenditures. However, if a compelling business purpose exists, an exception to this policy may be granted with the consent of the CEO, Government Affairs, and Legal. For the period January 1, 2023 – December 31, 2023, no contributions to independent expenditures were made by ConocoPhillips. Note, however, that our subsidiary, ConocoPhillips ANS Marketing Company, contributed to the Senate Leadership Fund, the Congressional Leadership Fund, and the Center Forward Committee, all of which are independent expenditure-only committees registered with the Federal Election Commission.  Information on this and other ConocoPhillips political expenses is provided as a 5-year rolling archive, inclusive of the current report. 

Certain trade associations incur independent expenditures, and we have engaged in discussions with stakeholders who have expressed concern about this trade association practice. As with prior reporting periods, ConocoPhillips continues to stipulate that none of our national trade association dues be applied to independent expenditures focused on the election or defeat of any federal candidates for the period January 1, 2023 – December 31, 2023.

Candidates and their supporters hold social activities as political fundraisers. Recognizing federal and many state laws impose restrictions, corporate funds for these activities require prior review and approval of Government Affairs and Legal. We occasionally contribute to ballot initiatives, get out the vote activities and partisan organizations such as the Democratic and Republican governors associations. These, too, require review and approval of Government Affairs and Legal. This information is provided as a 5-year rolling archive, inclusive of the current report. 

Corporate contributions to national political parties are illegal. Any such requests should be forwarded to Government Affairs given the potential for changes in the law and the need to monitor such requests. Contributions to state parties remain legal, but subject to varying limitations and reporting requirements depending on the state. All requests require Government Affairs and Legal review and approval.

ConocoPhillips may elect to participate in state or federal political party conventions. Although corporate contributions to political parties at the national level are prohibited by law, corporations may make contributions to the presidential conventions held by the parties through the host committees. Any such contribution requires the review and approval of Government Affairs and Legal.