Business ethics and compliance

Our reputation and integrity depend on every ConocoPhillips employee — and those working on our behalf — taking personal responsibility for business conduct. The Global Compliance and Ethics team, led by our Chief Compliance Officer, maintains adherence to applicable laws and the highest ethical standards, promotes a positive corporate reputation, and sets the tone for an ethical work environment across the company. Local ambassadors embedded in BUs and functions help support and administer our Global Compliance and Ethics program.

Our external auditor annually reviews aspects of our compliance and ethics program relevant to financial reporting while our internal audit function and external compliance experts periodically audit compliance and ethics processes.

Code of Business Ethics and Conduct 

Our Code of Business Ethics and Conduct is the foundation of our compliance and ethics program, addressing key topics including business ethics, competition law, anti-corruption, gifts and entertainment, conflicts of interest and political involvement.

All new employees receive ethics code training as part of onboarding, and employees have ongoing access to web-based training, with periodic refresher requirements. Employees in positions most exposed to legal risks, such as corruption, are required to attend additional training on topics including competition law, anti-boycott, anti-corruption, economic sanctions, export controls, insider trading and political activities. Each year, employees are required to certify they have read the code, made required disclosures and reported potential concerns. With exceptions for certain types of leave, 100% of employees completed this certification in 2025. 

Systems and practices for reporting ethics violations 

We encourage employees and contractors to ask questions and seek guidance about compliance and ethics and provide tools to support ethical decision making. Employees are responsible for reporting actual or suspected misconduct. There are numerous ways to report, including speaking with a manager, supervisor, human resources or a Global Compliance and Ethics representative.  Reports can also be made anonymously through our 24-hour Ethics Helpline which is available worldwide via web or phone, in multiple languages to employees, contactors, shareholders and the public. ConocoPhillips prohibits retaliation of any kind against employees who raise ethical or legal concerns. 

Global Compliance and Ethics receives and responds to questions, concerns and requests for guidance from employees and stakeholders across our businesses. In 2025, we responded to employee requests for guidance, investigated alleged code violations, and recommended remedial or disciplinary actions where appropriate. Senior management and the Audit and Finance Committee of the Board receive regular updates to ensure our program promotes the ConocoPhillips SPIRIT Values, addresses compliance and ethics risks, and operates effectively.