At ConocoPhillips, we are committed to our SPIRIT Values of Safety, People, Integrity, Responsibility, Innovation and Teamwork. It is essential that our suppliers remain fully aligned with those values to ensure the highest standards of operating excellence. The ConocoPhillips Code of Business Ethics and Conduct (Code) forms the foundation of our compliance and ethics program and provides concrete guidance for employees, suppliers and other stakeholders. Our contracts require that suppliers be guided in their performance for ConocoPhillips by the principles and standards set forth in the Code and their own ethics and conduct policies. We have developed this document to provide additional clarity to our suppliers regarding our expectations in this area.

Key Elements of ConocoPhillips Code of Business Ethics and Conduct

When contracting with ConocoPhillips, each supplier (whether providing goods or performing work or services) agrees to these principles and accordingly has included them in its own code of conduct (references below are to relevant page numbers in the Code):

Integrity

• Asking Questions and Reporting Concerns – Supplier will integrate its ethics policy into its operations and provide a mechanism for employees to report suspected misconduct anonymously, consistent with local law. Supplier will prohibit retaliation of any kind against employees for raising a health, safety, environmental (HSE), ethical or legal concern. (Pages 5 – 6)
• Avoiding Conflicts of Interest – Supplier will avoid taking part in or seeking to influence decisions on matters on which it has a conflict of interest. Supplier will not offer gifts to ConocoPhillips employees or representatives, with the limited exception of promotional items of nominal value. Supplier will not offer any hospitality that is not customary and acceptable in the industry. No gifts, hospitalities, nor anything of value shall be offered or provided during or in connection with contract bidding, evaluation or award. (Pages 16 – 18)
• Ensuring Fair Competition – Supplier will gather competitive information only by legal means and will not share confidential information belonging to ConocoPhillips or others without written permission. (Page 38) ConocoPhillips will only engage with suppliers who compete fairly and will not tolerate noncompetitive behaviors by suppliers - such as illegal bid rigging, price fixing and tying - in its procurement activities.
• Setting High Expectations for Suppliers and Contractors – Supplier will not knowingly use suppliers or contractors who operate unethically or who violate applicable laws. (Page 39) Supplier will promote the implementation of the principles set forth in this Expectations of Suppliers document with its own suppliers.
• Combating Corruption and Bribery – Supplier will conduct business in compliance with the principles set forth in the United States Foreign Corrupt Practices Act and any other applicable anti-corruption conventions, laws and regulations. Supplier will not offer, promise or give any improper advantage to a public official (or a third party) to cause the official to act or refrain from acting in relation to the performance of their official duties. This applies regardless of whether the advantage is offered directly or through an intermediary. (Page 45)
• Preventing Money Laundering – Supplier will prohibit participation in any form of money laundering and follow all domestic and international laws governing money laundering. (Page 47)
• Complying with International Trade Laws – Supplier will comply with all applicable international trade control laws and regulations. (Import and Export Control Laws, applicable Economic Sanctions and Anti-boycott Laws.) (Page 48)
• Preserving Data Privacy – Supplier will comply with all applicable Privacy Laws. (Page 14)

Labor and Human Rights

• Preventing Harassment and Discrimination – Supplier will provide equal opportunity to all employees and candidates for employment and will promote employees based on skills and performance. Supplier will not accept any form of harassment or discrimination. (Page 11) Supplier will comply with local law or agreements regarding working hours, ensure employee compensation meets or exceeds the legal standards and requirements, and treat employees equally and fairly.
• Advancing Respect for Human Rights – Supplier will conduct its business consistent with our Human Rights Position, including but not limited to (Page 13): 
  • Not knowingly participating in human trafficking.
  • Not using child labor or forced labor, such as prison labor, forcibly indentured labor, bonded labor, slavery or servitude.
  • Recognizing freedom of employees to join, or refrain from joining, legally authorized associations or organizations.
  • Conducting human rights due diligence in order to identify, prevent, mitigate and account for adverse human rights impacts.
• Supplier will observe strict requirements for the selection of security contractors to avoid human rights risks in countries where security firms are not properly regulated.

Health, Safety and Environment

• Creating a Safe Workplace – Supplier will comply with all applicable health and safety rules, laws and regulations, as well as all posted safety procedures in ConocoPhillips’ areas of operation. Supplier will implement programs, training, audits and internal controls necessary to achieve compliance. (Page 8) Supplier will utilize energy and natural resources efficiently, seek to reduce greenhouse gas emissions and manage waste, emissions and discharges responsibly. 

Sustainable Development

• Supporting Environmental Sustainability – Supplier will commit to environmental stewardship around the world. Supplier will follow all applicable environmental laws and regulations and conduct its business with respect and care for both the local and global environment. (Page 42) Supplier will promote safe work practices and avoid risk to neighbors and the environment. (Page 9) Supplier will utilize energy and natural resources efficiently and manage waste, emissions and discharges responsibly.
• Supporting Social Sustainability – As set out in our Code and our SPIRIT Values, ConocoPhillips is a good neighbor and citizen in the communities where we operate. Supplier is expected to share our goal of promoting an inclusive business model and creating shared value with local communities. Supplier should, where possible, source goods and services locally and from diverse companies and promote development of sub-suppliers through capacity building in order to stimulate local economic development and create long-lasting benefits to communities. (Page 9)