Combating Corruption

ConocoPhillips is opposed to corruption in all forms. We act in accordance with all U.S. laws and regulations regarding business gratuities that may be accepted by U.S. government personnel, and we comply with the Foreign Corrupt Practices Act (FCPA) and similar anti-corruption laws. The FCPA prohibits corruptly giving anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates in order to obtain or retain business. It strictly prohibits illegal payments to government officials of any country.

ConocoPhillips provides online compliance training to employees, joint-venture personnel, seconded employees and contractors who may be exposed to issues relating to anti-corruption laws, export and import compliance, and U.S. sanctions regulations. Additionally, company attorneys provide yearly in-person lecture sessions for personnel dealing with anti-corruption issues in high-risk locations. Because of the global scope of our U.S.-based business, we offer accommodations to implement ethics and FCPA training and expectations. For example, online FCPA compliance training is available in Arabic, Bahasa Indonesian, Chinese, English, German, Norwegian, Russian and Spanish.

The training covers company policy, the FCPA, the OECD Convention on Combating Bribery in International Transactions, and other international and local anti-bribery codes. It discusses actions employees can take to avoid corruption, perform due diligence, and recognize situations where corruption could occur. Through case studies, employees are taught how to identify local anti-corruption laws and various corruption-related business risks, including those created by third parties, inaccurate accounting, and inadequate controls that arise in connection with travel, hospitality, gifts and charitable contributions.