Business ethics and compliance training and reporting
Our reputation and integrity depend on every ConocoPhillips employee — and those working on our behalf — assuming personal responsibility for business conduct. With oversight from our Chief Compliance Officer, our Global Compliance and Ethics team maintains 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 across the company. The team includes local ambassadors who are embedded in BUs and functions and help support and administer our Global Compliance and Ethics program.
Our external auditor annually reviews aspects of our compliance and ethics program relevant to financial reporting while our internal audit function and external compliance experts periodically audit global compliance and ethics processes.
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.
All new employees receive business ethics code training 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 in positions that are most exposed to legal risks, such as corruption, take part in web-based training and other targeted training. Employees may also receive training in 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 2023.
Systems and practices for reporting ethics 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. Employees 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.
Global Compliance and Ethics receives questions, concerns and requests for advice from employees and stakeholders across our businesses. In 2023, we responded to these submissions and investigated alleged violations of our code. Remedial and disciplinary actions were taken whenever appropriate to support our commitment to ethics. 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 the ConocoPhillips SPIRIT Values, addresses the compliance and ethics risks in our business, and works effectively.
