The purpose of this form is for ConocoPhillips employees to disclose any conflict of interests they may have prior to the year-end Annual Ethics Compliance Certification Process.

A “conflict of interest” occurs when our private interests interfere in any way with the interests of the company. A conflict can arise if we take on outside work or make financial investments that make it difficult for us to perform our work at ConocoPhillips objectively and effectively. A conflict also can occur if employees or members of their family receive personal benefits as a result of the employee’s position in the company.

Items marked with a red diamond ♦ are required fields and must be completed before submitting the report.

Employee Information

Your Information

♦ First Name:

M.I.

♦ Last Name:

 

♦ User ID (i.e. jsmith24):

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Conflict of Interest Disclosure Statement

Disclosure

♦  As a ConocoPhillips employee, I have read and understand the Conflict of Interest section within the ConocoPhillips Code of Business Ethics and Conduct and declare that:

To the best of my knowledge neither, I nor a member of my extended family, is engaged in any activities that may be perceived as conflicting with the best interest of ConocoPhillips. I also understand that if a conflict should arise prior to the Annual Ethics Compliance Certification process, I am required to disclose this to my supervisor.
A possible conflict of interest may exist and I have provided an explanation of it on this form.

Possible conflicts include, but are not limited to:
  • Employees working for suppliers, contractors or customers.
  • Ownership by the employee or, to the employee’s knowledge, by a member of the employee’s family of a significant financial interest in any outside enterprise which does or seeks to do business with or is competitor of the company.
  • Holding significant business interests in oil and natural gas leases, royalties or mining interests. This includes any interest held by the employee and immediate family members, including interests acquired as an inheritance or gift.
  • An employee or a member of the employee’s extended family serving as a director, officer, partner, consultant or contractor of, or in a managerial position with, or employment in a technical capacity by, any outside enterprise which does, or is seeking to do, business with or is a competitor of the company.
  • Acting as a broker, finder, go-between or otherwise for the benefit of a third party in transactions involving or potentially involving the company or its interests.
  • Any other arrangement or circumstance, including family or their personal relationships, which might dissuade the employee from acting in the best interest of the Company.
X
Extended Family
Extended family includes your or your spouse's relatives such as parents, siblings, cousins, aunts, uncles, nieces, nephews, grandparents, regardless of whether they are first or second or great-great-grand or "once removed," etc.
X
Significant Financial Interest
As a minimum standard, a "significant" financial interest is a direct or indirect aggregate interest of an employee and family members of more than:
  • 1% of any class of the outstanding securities of a firm or a corporation.
  • 10% interest in a partnership or association.
  • 5% of the total assets or gross income of such employee.
See the"Conflicts of Interest" section of the Code of Business Ethics and Conduct booklet for additional related guidance.

♦ Explanation of Possible Conflict

Acknowledgement and Submission

Acknowledgments
♦ As a ConocoPhillips employee, I understand it is my responsibility to take action to eliminate the conflict of interest or the perception of a conflict of interest. I understand that conflicts should be fully disclosed (in writing as necessary) to my supervisor for review and approval as soon as the conflict occurs, in order that proper controls are put into place to eliminate the potential for a conflict of interest.
♦ I understand that ConocoPhillips employees who knowingly fail to disclose conflicts are subject to discipline, including dismissal.
♦ I understand that I am expected to note conflict of interest situations on each annual ethics compliance certification form as long as the conflict, or potential conflict, of interest continues.
♦ I understand that senior management and the Global Ethics Office may decide it is in the best interest of ConocoPhillips for me to disassociate myself with the conflicting interest or the perception of a conflict of interest, which could mean reassigning job duties or authorities to eliminate the potential for a conflict of interest.
♦ The information contained in this form is true and accurate to the best of my knowledge and belief as of today.
If you ever have an ethics question to ask or unethical behavior to report, please call the Ethics HelpLine at 877-327-2272 (within the U.S. or Canada) or for outside the U.S. and Canada click here. The Ethics HelpLine can also be reached online at www.ConocoPhillips.EthicsPoint.com, while the ConocoPhillips Global Ethics Office can be reached via email at Ethics@ConocoPhillips.com.
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