A number of local, state and federal laws exist that govern corporate involvement in activities of a political or public policy nature. These statutes contain numerous prohibitions and detailed reporting and record-keeping requirements. They also contain enforcement provisions that carry civil and criminal penalties for noncompliance. Employees may be asked to participate in activities that fall under the jurisdiction of one or more of these statutes.

The policies and guidelines below have been approved by the Public Policy Committee of the board of directors and are intended to help ensure corporate compliance with these laws and regulations. With respect to political contributions, all such contributions will promote only the interests of ConocoPhillips, and not the personal political preferences of its company officers and executives.

These policies and guidelines deal primarily with U.S. domestic political activity, and are not intended to cover the many global political, legal and business issues that apply to U.S. corporations and their international affiliates. Other countries' rules and U.S. rules, such as the Foreign Corrupt Practices Act, are covered under other policies. Additionally, the policies and guidelines below only apply to situations where employees are asked to act on behalf of the company and do not apply to personal activities employees choose to fund or pursue at their own cost and on their own time.

In addition to undergoing a voluntary, internal assurance audit of our corporate political expenditures each year, we assess our political policies on a regular basis and in light of changes in federal, state and local lobbying and campaign finance laws and regulations. For the period January 1, 2013, through December 31, 2016, we adhered to our own code for corporate political spending.

Policies & Guidelines

These policies and guidelines have been approved by the Public Policy Committee of the Board of Directors and are intended to help ensure corporate compliance with campaign finance laws and regulations.

Gifts to Elected Officials, Regulators and Government Employees

Federal law prohibits registered federal lobbyists and those entities that employ federal lobbyists (such as ConocoPhillips) from providing gifts or anything of value to members of Congress or Congressional staffers. This includes appreciation gifts, items for display in his or her office, as well as tickets to sporting or other events. It also includes meals and lodging. While the rules provide for selected exceptions, great care is required to ensure compliance. Separate and similarly strict gift rules apply to the executive branch of the federal government. Additionally, states and localities have various types of gift rules, some with very strict gift prohibitions and reporting requirements.

Any gift to an elected official or government employee made on behalf of the company must comply with the applicable gift ban rules and receive prior approval from Government Affairs.

Lobbying & Grassroots Activities — Government Contacts

Federal, state and local statutes govern corporate lobbying activities. These statutes require activities and expenses associated with working legislative and regulatory issues be reported regularly and in prescribed ways. Contacts with officials and other efforts to influence government action, including permitting or licensing of company operations, may constitute lobbying activities under various state and local laws.

While the Federal Lobbying Disclosure Act exempts infrequent contacts with federal lawmakers, advanced consultation with Government Affairs is essential to confirm the ground rules for these discussions and proper reporting. Consultation with Government Affairs is also required for contacts with state and local policymakers. This is especially important given the wide variation in rules by state and locality.

Additionally, our employees should refrain from the following activities at the state or federal level without prior internal consultation and approval from Government Affairs.

  • Testifying before a legislative or regulatory body.
  • Agreeing to share in the costs of retaining a firm or individual to work a regulatory or a legislative issue.
  • Agreeing to join an association or coalition whose purpose is to influence a regulatory or legislative issue.
  • Lending ConocoPhillips’ name to any effort to endorse or oppose a pending legislative or regulatory issue.

Lobbying-related Activities — Trade Association Membership

We actively engage with trade associations at the national, state and local levels and encourage our employees to represent the interests of the company and the communities in which we operate through participation in committees and/or leadership roles in these associations. While not the primary motivation for joining or maintaining membership in any trade association, many such organizations actively engage in lobbying. Employees who serve on trade association committees that are advocating legislation or regulation must work closely with Government Affairs, affected business units and Legal to develop appropriate positions and ensure compliance with any possible lobbying disclosure requirements.

With respect to trade association contributions, our primary purpose in joining groups such as the National Association of Manufacturers, the U.S. Chamber of Commerce, and the American Petroleum Institute is not for political purposes, nor does the Company agree with all positions taken by trade and industry associations on issues. We are one of many voices in these organizations and value the diversity of opinions that may be presented in these groups. We publicly acknowledge that we do take positions contrary to those of trade associations from time to time. The greater benefits we receive from trade and industry association memberships are the general business, technical and industry standard-setting expertise that these organizations provide. Through participation in trade associations involved in lobbying, we seek to champion legislative solutions that are practical, economical, environmentally responsible, non-partisan and in the best interests of the company. We engage with hundreds of trade associations at the national, state and local levels, and in the vast majority of instances our membership and involvement isn’t based on a single issue. For the past 6 months, as indicated in our U.S. government filings, our lobbying priorities have included:

  • Methane emissions
  • Endangered species
  • Taxes
  • Trade Regulation
  • Operations and development

These priorities are in alignment with our policies and positions, including our climate change public policy principles.      

We also annually report on trade association memberships with dues in excess of $50,000.     

Issue Advocacy

For our business purposes, issue advocacy is the support of a pro-energy and/or pro-business position regarding a ballot initiative to be voted on by the people. Issue advocacy may also include support of an initiative that would defeat anti-energy and/or anti-business measures. Actions typically include development and distribution/broadcasting of information either jointly or solely, and may include signature gathering on initiative petitions which the company has expressly supported. We will be active in such issues, provided there is a compelling business rationale; an agreement to participate among the affected business units and Government Affairs personnel and management; and where there is distribution/broadcasting of information, significant ConocoPhillips and/or energy industry involvement, input and approval of the message development and the tactics taken in the initiative process.