Governance and Management Systems

The ConocoPhillips Health Safety and Environment (HSE) Policy is the foundational HSE document for ConocoPhillips. A component of this policy, the HSE Management System Standard, provides corporate expectations for each individual business unit’s HSE Management System and is the primary tool that our business units use to execute the contents and commitments contained within the company’s HSE Policy. Key elements of the HSE Management System include risk assessment, incident and near miss reporting and investigation, onsite job safety analysis, HSE training, audits, and annual review and goal setting.

Through the execution of the HSE Management System Standard, a variety of deliverables are generated by each business. Some of these include investigation reports of "high and significant risk" incidents, audit findings and HSE Compliance Verification Reports. The Corporate Safety and Performance Assurance Group maintains a listing of all open investigation and audit findings that are rated "high and significant risks" by the ConocoPhillips Risk Matrix and tracks timely closure of the investigations. A monthly report that highlights HSE performance, process safety experience and a listing of open items is electronically communicated via the company intranet site and is therefore accessible to all employees. Both the ConocoPhillips Management Committee and Public Policy Committee of the company’s Board of Directors receive regular updates of key HSE issues, events and performance from the vice president of HSE.

ConocoPhillips maintains a multi-tiered risk based HSE audit program encompassing regulatory and management system compliance audits at both the Corporate and Business Unit levels. Our program also includes external insurance risk assessments. Ernst & Young conducts a limited assurance engagement on ConocoPhillips’ corporate level processes for collating and reporting aggregated HSE data presented in ConocoPhillips’ Sustainable Development report.

Integrated into our Risk Matrix Standard and Upstream Projects Safety Case Standard is the requirement to reduce all high and significant rated risks to low or medium. If the risk is rated medium, additional assessments must be done to determine if the risk can be further reduced or if it is truly as low as reasonably practicable. The ConocoPhillips Risk Matrix is a qualitative or semi-quantitative assessment. ConocoPhillips will conduct quantitative risk assessments when and where regulatory and permitting agencies have established quantitative risk criteria.

ConocoPhillips is committed to complying with the law wherever we operate and to conducting our business activities with the highest ethical standards. Employees and contractors are provided with several channels to confidentially report actual or suspected violations of the policies, principles and procedures outlined in the ConocoPhillips Code of Business Ethics and Conduct. Reports may be submitted through our Ethics Helpline, which includes an option to make anonymous reports and is accessible 24/7 via telephone and web. Reports may also be made directly to our Global Ethics Office via mail, e-mail and telephone. All issues are tracked to resolution. Retaliation against anyone who reports a concern in good faith will not be tolerated. The company’s Chief Compliance Officer regularly reports to the Audit and Finance Committee of the Board of Directors on significant issues raised through these processes.

ConocoPhillips, as a publicly-traded U.S. company, is required to maintain disclosure controls and procedures designed to ensure that periodic reports filed with the Securities and Exchange Commission (SEC) include all information that is considered material by a reasonable investor relating to the period being reported. In this regard, ConocoPhillips regularly reviews and updates the material risks disclosed in its filings with the SEC to ensure that these reports accurately and adequately describe the material risks to the company's investors.