California Transparency in Supply Chains

ConocoPhillips recognizes that slavery and human trafficking are crimes under state, federal, and international laws. We also recognize slavery and human trafficking likely exist in every country, including the United States, and the State of California. ConocoPhillips knows a safe and secure supply chain is critically important to the success of our business. A secure supply chain helps prevent slavery and human trafficking, while ensuring the safety of employees, our customers, and the communities in which we operate.

ConocoPhillips is committed to the California Transparency in Supply Chains Act of 2010. The objectives of the Act are reflected in many Company programs, policies and standards, several of which are quoted below. As the operator of critical infrastructure and manufacturer in the State of California, ConocoPhillips will continuously seek out and implement security best practices that reduce vulnerabilities in our supply chain and advance our SPIRIT goals.

ConocoPhillips Programs & Standards Applicable to
the California Transparency in Supply Chains Act of 2010

  1. US Customs & Border Protection (USCBP) Customs – Trade Partnership Against Terrorism (C-TPAT) – C-TPAT is a voluntary US Government program designed to increase security and prevent slavery and human trafficking throughout the global supply chain. The C-TPAT program includes both internal and independent external announced and unannounced audits of suppliers. It also requires our suppliers comply with laws regarding slavery and human trafficking.

    USCBP has evaluated the security programs of over 10,000 companies that import into the United States and participate in the C-TPAT program. ConocoPhillips is one of only 329 top tiered certified participants in C-TPAT. We have actively participated in the C-TPAT program and maintained a top tier status since 2007.

  2. Corporate Code of Conduct – This Code of Business Ethics and Conduct covers a wide range of business practices and procedures. It sets out basic principles to guide all employees and directors of the Company. All must conduct themselves accordingly and seek to avoid even the appearance of improper behavior. The Code is provided to and must be followed by the Company’s agents and representatives, including consultants. Those who violate the standards in this Code are subject to disciplinary action.

  3. Commercial Commitment Statement – Commercial leadership is committed to creating and maintaining a culture where Commercial employees worldwide share a common responsibility to adhere to the highest standards of integrity and fair dealing and to comply with the spirit as well as the letter of the law, regulations and policies that govern our business and activities, which includes those laws prohibiting slavery and human trafficking.

  4. Commercial Code of Conduct – The Commercial Code of Conduct sets out the accepted standards, behaviors and duties by which all Commercial employees and contractors must abide. The purpose of this policy is to communicate an expectation of ethical conduct to all Commercial employees, and should be understood and followed in conjunction with the Corporate Code of Conduct.

  5. Commercial Trading Policy – The Commercial Trading Policy sets out high level trading standards by which all Commercial employees with the authority to transact [commercial transactions?] must abide. The purpose of this policy is to communicate the rules of engagement to all transacting Commercial employees.

  6. Commercial Authority Limitations – This document helps ensure we are dealing with reputable business partners by defining the authorities delegated by the Board of Directors (Board) of ConocoPhillips (the Company) to the Chief Executive Officer (CEO) and from the CEO to others in the Company. Items requiring Board or CEO approval and authority levels of the Group Heads and Staff Heads are identified as they pertain to capital expenditures, expense authorization, contract approvals and other commitments of Company resources.

  7. Global Marine Vetting Standard – This document establishes a corporate-wide Standard for Vessel Vetting and Marine Terminal Clearance for Vessels used in ConocoPhillips business to assure prudent management of marine risks. Global Commercial Marine Risk Management Group and Global Production Marine Operations Group have authorized and implemented global processes necessary for Vetting of marine Vessel service providers and their equipment. This Standard applies to all Vessels:

    1. Contracted for ConocoPhillips use;

    2. Contracted on behalf of ConocoPhillips by an external party;

    3. Contracted by any ConocoPhillips Entity;

    4. Ship To Ship Transfer Operation of a ConocoPhillips Commercial Cargo, including both the discharging Vessel, receiving Vessel, and lightering service company;

    5. Vessels loading, discharging, tank cleaning, conducting repairs, or along side at a marine terminal/facility that is owned, or operated by a ConocoPhillips Entity; and

    6. Vessels carrying ConocoPhillips titled/owned Commercial Cargo."

    The Marine Vetting program includes both internal and independent external announced and unannounced audits. It also requires our suppliers comply with laws regarding slavery and human trafficking.

  8. Pre-Placement Screening Policy – All offers of employment with ConocoPhillips in the U. S. are contingent upon the satisfactory completion of a pre-placement screening of the candidate's application, resume and other biographical data provided by the applicant. Routinely, this check will include: a Social Security Number trace; a criminal record check for felony convictions, misdemeanor convictions negotiated from a felony charge or any misdemeanor conviction for theft, violence, fraud or moral turpitude (including slavery or human trafficking); verification of education; verification of prior employment for the past seven years; and a check against various restricted parties lists administered by both the U.S. and non - U.S. countries.

  9. Export Compliance Policy – This policy helps ensure we are dealing with reputable business partners by requiring that all transactions must be screened to ensure ConocoPhillips is not conducting business with applicable Restricted Party and Embargoed/Sanctioned Countries, and to address end use and red flag concerns. Transactions may include export or re-export, import, financial or other business activity (including non-exports), and could include transactions involving nationals of embargoed or sanctioned countries.

  10. Training – Management, employees and contractors, who have direct responsibility for supply chain management, receive periodic awareness training concerning supply chain security, slavery and human trafficking, our C-TPAT program, Ethics Hotline Reporting System, and other security threats within the supply chain.

Additional Information – For questions or additional information regarding our continuing efforts to supply products free from slavery and human trafficking, please contact:

John Roper
+1 281-293-2073
Roperj@ConocoPhillips.com