Case study: How ConocoPhillips promotes ethical business conduct
ConocoPhillips is a multinational corporation engaged in hydrocarbon exploration, based in the Energy Corridor district of Houston, Texas, with operations in 17 countries. Led by its Chief Compliance Officer, ConocoPhillips’ Global Compliance and Ethics team was established to ensure adherence with applicable laws and the highest ethical standards Tweet This!, promote a positive corporate reputation, prevent criminal and civil liability, and set the tone for an ethical work environment.
This case study is based on the 2019 Sustainability Report by ConocoPhillips published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.
Abstract
ConocoPhillips’ reputation and integrity depend on each employee, officer, director and those working on its behalf assuming a personal responsibility for its business conduct. In order to promote ethical business conduct ConocoPhillips took action to:
- implement a Code of Business Ethics and Conduct
- encourage employees and contractors to raise concerns
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With this case study you will see:
- Which are the most important impacts (material issues) ConocoPhillips has identified;
- How ConocoPhillips proceeded with stakeholder engagement, and
- What actions were taken by ConocoPhillips to promote ethical business conduct
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What are the material issues the company has identified?
In its 2019 Sustainability Report ConocoPhillips identified a range of material issues, such as energy efficiency, community impacts, water sourcing, human rights, safety and health. Among these, promoting ethical business conduct stands out as a key material issue for ConocoPhillips.
Stakeholder engagement in accordance with the GRI Standards
The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:
Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.
Key stakeholder groups ConocoPhillips engages with:
| Stakeholder Group | Method of engagement |
| Financial Sector
| · Investor presentations and conferences · Analyst calls · Annual Shareholder Meeting · SEC filings · Socially Responsible Investor meetings and conferences · Tours |
| Governments
| · Advocacy · Policy development · Industry and trade association representation · Regulatory compliance · Permit reviews · Regulatory audits · Regional development · Tours · Collaboration on community investment projects · Town halls · Multi-stakeholder initiatives |
| Communities
| · Websites, media and social media · Community investment programmes · Royalty relations · Community consultations · Local procurement · Employment · Landowner meetings · Town halls · Volunteering |
| Employees
| · Performance management · Training and development · Internal communications · Code of Conduct · Employee surveys · Participation on trade and industry association committees · Safety meetings · Ethics Helpline · Volunteering · Leadership town halls · Employee network groups · Talent Management Teams · Global wellness programmes · 360-feedback tool |
| Suppliers
| · Bid process · Contract negotiations · Project management · Supplier forums · Annual performance reviews |
How stakeholder engagement was made to identify material issues
To identify and prioritise material topics ConocoPhillips engaged with its key stakeholders through meetings and discussions.
What actions were taken by ConocoPhillips to promote ethical business conduct?
In its 2019 Sustainability Report ConocoPhillips reports that it took the following actions for promoting ethical business conduct:
- Implementing a Code of Business Ethics and Conduct
- ConocoPhillips’ Code of Business Ethics and Conduct explains ConocoPhillips’ standards as well as its legal and ethical responsibilities and provides concrete guidance for expected behaviours. It covers a range of topics including business ethics, anti-trust, anti-corruption, gifts and entertainment, and political involvement. New employees receive training on the Code of Business Ethics and Conduct and all employees receive web-based training periodically. All employees are also required to read the code annually and confirm compliance. Employees who are most exposed to legal risks, like corruption, take part in web-based training and other targeted training. In addition to corruption training, ConocoPhillips also teaches employees how to deal with situations that may involve laws or regulations regarding political activities, antitrust, economic sanctions or export controls.
- Encouraging employees and contractors to raise concerns
- ConocoPhillips encourages employees and contractors to ask questions and seek guidance about ethical concerns and gives them tools to guide ethical decision-making so they can understand their responsibility to report actual or suspected misconduct. ConocoPhillips has several confidential reporting mechanisms, including speaking to a trusted manager, supervisor, human resource representative or a Global Compliance and Ethics representative. Additionally, there is an anonymous option. Any stakeholder, whether employee, contractor, shareholder or the general public may report an actual or suspected violation anonymously through ConocoPhillips’ 24-hour Ethics Helpline. The Ethics Helpline is hosted by a third party to ensure anonymity and is available worldwide via the web or phone in multiple languages. ConocoPhillips prohibits retaliation of any kind against employees for raising an ethical or legal concern. In 2019, Global Compliance and Ethics received questions, concerns and requests for advice from employees and stakeholders across ConocoPhillips’ ConocoPhillips investigated workplace conduct, conflicts of interest, financial and business integrity matters, misuse of company assets and other allegations. Depending on the scale and type of concern, issues were elevated to provide appropriate management oversight. Additionally, appropriate remedial and disciplinary action was taken when necessary. Senior management and the Audit and Finance Committee of the board are also provided regular updates on ConocoPhillips’ compliance and ethics programme, so they can ensure that the programme promotes ConocoPhillips’ SPIRIT values, addresses the compliance and ethics risks in its business and works effectively.
Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?
The GRI Standards addressed in this case are:
1) Disclosure 205-1 Operations assessed for risks related to corruption
2) Disclosure 205-2 Communication and training about anti-corruption policies and procedures
Disclosure 205-1 Operations assessed for risks related to corruption corresponds to:
- Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
- Targets: 16.5
Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:
- Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
- Targets: 16.5
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References:
1) This case study is based on published information by ConocoPhillips, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:
http://database.globalreporting.org/
2) https://www.globalreporting.org/standards/gri-standards-download-center/
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